Loans are called “mútuo” in Brazilian Law, and are defined as the transferences of fungible goods, that can be changed by others of the same gender, quality and quantity. The rules over the money loans are disposed in Brazilian Civil Law Code. Money loans are a special kind which has the incidence of a specific tax. Over the money loans there is the incidence of the IOF (Financial Operations Tax), as a general rule, like disposed in the section 2 of the Decree 6.306, from December the 14 th of 2007. The tax shall be paid by the taxpayer at the date it receives the values, total or partially. On the other hand, international money loans have different rules about the taxation by the Financial Operations Tax. The Federal Government, by the Decree 8.325, from October the 07 th of 2014, changed the rules about the IOF, by adding the section 15-B and revoking the section 15-A, of the Decree 6.306/2016. Posteriorly, the section 15-B was changed by the Decree 8.731, fr