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This publication is intended to provide information for businesses and individuals regarding the Brazilian legal system. It has been prepared for general guidance on matters of interest only, is intended for information and summary in


  1. This publication is intended to provide information for businesses and individuals regarding the Brazilian legal system. It has been prepared for general guidance on matters of interest only, is intended for information and summary in nature. It has been prepared by and is the property of Leal Cotrim Advogados. This publication does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional legal advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, Leal Cotrim Advogados, its members, and employees do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining from acting, in reliance on the information contained in this publication or for any decision based on it. Companies or individuals seeking an opinion concerning specific issues of the laws of Brazil are encouraged to contact Leal Cotrim Advogados, whose contact information is available online at www.lealcotrim.com.br.

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  6.          INFLOW OUTFLOW PAYMENT OF CAPITAL IOF 0.38% N/A DISTRIBUTION OF PROFITS N/A N/A NATIONALISATION OF SHARES N/A 15% OR 25% TRANSFER OF LOANED FUNDS IOF 6% IF < 189 DAYS N/A REPAYMENT OF LOANED FUNDS N/A TAX EXEMPT PAYMENT OF INTERESTS N/A 15% OR 25%

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  8. • 41.03% 15.7%

  9. 100.000,00 100.000,00 Invoice amount TAX RATE TAX BURDEN TAX RATE TAX BURDEN 15,00% 15.000,00 N/A N/A WHT/IRRF 85.000,00 Received by Norwegian based Co. 1,65% 1.909,09 1,65% 1.909,09 PIS COFINS 7,60% 8.793,39 7,60% 8.793,39 5,00% 5.000,00 5,00% 5.000,00 ISS IOF 0,38% 323,00 N/A N/A 10,00% 10.000,00 N/A N/A CIDE 39,63% 14,25% Nominal Tax Burden 41.025,48 15.702,48 41,03% 15,70% 126.025,48 100.000,00 N/A N/A N/A 85.000,00 N/A 84.297,52 WHT/IRRF COULD BE OFFSET WITH INCOME TAX IN NORWAY CLIENT IS TAXPAYER FOR PIS, COFINS, ISS AND CIDE LOCAL SUPPLIER IS TAXPAYER FOR PIS, COFINS AND ISS OFFSET OF CREDITS WITH PIS AND COFINS UNDER NON- CUMULATIVE SYSTEM PIS AND COFINS 3,65% COMBINED TAX RATE UNDER CUMULATIVE SYSTEM INCOME TAX (IR + CSLL) ACCORDING TO PROFIT REGIME ADOPTED OTHER WITHHOLDING TAXES (IR, CSLL, PIS, COFINS, ISS) MAY APPLY, ACCORDING TO THE SERVICE PROVIDED

  10. 100.000,00 100.000,00 Invoice Amount TAX RATE TAX BURDEN TAX RATE TAX BURDEN 20,00% 20.000,00 N/A N/A II 10,00% 12.000,00 10,00% 10.000,00 IPI 18,00% 23.759,97 18,00% 21.951,22 ICMS PIS 2,10% 2.100,00 1,65% 1.909,09 9,65% 9.650,00 7,60% 8.793,39 COFINS 0,38% 380,00 N/A N/A IOF 60,13% 37,25% Nominal Tax Burden 67.889,97 42.653,70 67,89% 42,65% 167.889,97 100.000,00 N/A N/A N/A 100.000,00 N/A 57.346,30 CLIENT IS TAXPAYER FOR II, IPI, ICMS, PIS, AND COFINS OFFSET OF CREDITS FROM TAXES PAID ON PREVIOUS OPERATIONS (IPI, ICMS, AND PIS/COFINS UNDER NON- PIS AND COFINS 3,65% COMBINED TAX RATE UNDER CUMULATIVE SYSTEM) LOCAL SUPPLIER IS TAXPAYER FOR IPI, ICMS, PIS, AND COFINS INCOME TAX (IR + CSLL) ACCORDING TO PROFIT REGIME ADOPTED CUMULATIVE SYSTEM

  11.   GOODS APPLIED IN O&G EXPLORATION AND PRODUCTION , LISTED IN ANNEXES I AND II   LINES, DUCTS, UMBILICALS, FLOWLINES/RISERS, CHRISTMAS TREES, MANIFOLDS   DRILL PIPES   STRUCTURES FOR PLATFORMS SUPPORT   5 YEAR USE PERIOD     

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  15. RATE BASIS AMOUNT GROSS MONTHLY SALARY • BRL 10.000,00 LABOUR BENEFITS ❶ ❷ 1.111,00 • Gross monthly salary Vacation additional pay (1/3) 2,78% 278,00 • Gross monthly salary Christmas bonus/13th salary 8,33% 833,00 TAXES ❶ ❸ 4.088,85 20,00% • Gross monthly salary + Social Security Contribution (INSS) 2.222,20 labour benefits • Gross monthly salary + Social Security Contribution for 3,00% 333,33 Occupational Accident Insurance (RAT) labour benefits ❹ • Gross monthly salary + Social Security Contributions for 3rd 5,80% 644,44 parties ( Terceiros ) labour benefits • Gross monthly salary + Employee Severance Indemnity Fund 8,00% 888,88 Contribution (FGTS) labour benefits TOTAL EMPLOYER MONTHLY COST 15.199,85 ❶ Paid and borne by employer. ❷ Rates correspond to monthly provision. ❸ Basis includes, in addition to the sum of employees' salaries, other amounts paid by the company, such as compensation to independent contractors. ❹ Tax rate may be 1%, 2% or 3% depending on employer's activities. Additionally, rates may be reduced up to 50% or increased up to 100% depending on statistics calculation of accidents suffered by employers vis-à-vis industry standards.

  16. RATE BASIS AMOUNT CALCULATION OF NET MONTHLY SALARY Gross monthly salary 10.000,00 Reductions -2.501,67 • Gross monthly salary Withholding income tax 27,50% -1.880,64 • 869,36 allow ance • Gross monthly salary Social Security Contribution 11,00% -621,03 • Cap BRL 621.03 per employee Net monthly salary 7.498,33 Net monthly salary considering 13th salary 8.123,19 COMPARISON EMPLOYEE SALARY EMPLOYEE SALARY GROSS NET 10.000,00 8.123,19 + 52,00% 87,12% EMPLOYER COST 15.199,85 15.199,85

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