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Practice areas

Taxation of Payments

Tax treatment of payment portfolios, merchant acquiring, processing and receivables transactions.

Taxation of payment methods requires understanding who provides each service and how funds circulate. Amounts passing through for transaction settlement are not necessarily the same as the participant's own revenue. Fees, acquiring remuneration, technology services and credit transactions must be identified separately. Legal qualification is also relevant in assignments and advance purchases of receivables, which may have different structures despite being given similar names in the market.

The analysis takes into account contracts, tax documents, accounting records and the rules applicable to the period of the transaction. Taxes levied on services and financial transactions are examined, along with relevant withholdings and ancillary obligations. Reforms and transition regimes require a review of their effects on the payment chain, without automatically applying the same treatment to all participants. The legal work seeks to document consistent classification criteria and assess contingencies related to revenue, pass-through amounts, discounts and partner remuneration.

Our work

  • Tax classification of revenue and pass-through amounts
  • Analysis of assignments and advance purchase of receivables
  • Review of contracts, withholdings and ancillary obligations

Does every advance purchase of receivables receive the same tax treatment?

No. It is necessary to distinguish the contractual and economic structure, the participants and the nature of the transaction, including to assess any incidence of tax on financial transactions.

Editorial review:

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