On July 7, 2025, the Brazilian Internal Revenue Service (IRS) published Notices No. 4/2025 and No. 5/2025, introducing new modalities of tax settlement by adhesion within the scope of administrative tax litigation, with...more
On June 27, 2025, Rio de Janeiro Governor enacted Decree No. 49,703 (the “Decree”), establishing compliance procedures for the obligations described in Rio de Janeiro State Law No. 10,456/2024, which relates to energy...more
The Brazilian Attorney General's Office of the National Treasury (PGFN) has published PGDAU Notice No. 11/2025 (the “Notice”), which sets forth the conditions for tax settlements to regularize debts up to BRL 45 million...more
The Second Panel of the Brazilian Superior Court of Justice (STJ) recently issued a significant decision regarding the time limit for the offset of tax credits recognized in final and unappealable judicial decisions. The...more
On May 13, 2025, the Brazilian Federal Revenue Service (IRS) published Normative Instruction no. 2,265/2025, which amends the Brazilian black and gray lists established by Normative Instruction no. 1,037/2010....more
The Brazilian Supreme Court (STF) decided that the Tax on Services’ (ISS) non-levy on toll commissioned manufacturing activities, whenever these activities refer to the intermediary activities of a production cycle. The...more
3/12/2025
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Constitutional Challenges ,
Corporate Taxes ,
Manufacturers ,
Regulatory Reform ,
Regulatory Requirements ,
State and Local Government ,
State Taxes ,
Tax Credits ,
Tax Planning ,
Tax Reform ,
Taxation
On February 4, 2025, and by unanimous vote, the Brazilian Supreme Court’s (STF) Plenary confirmed that the non-levy of ICMS will only apply from the 2024 fiscal year, with the exception of administrative and judicial...more
On January 20, 2025, the PGFN/MF Ordinance No. 95/2025 (the “Ordinance”) was published in the Federal Official Gazette, regulating the dismissal of debt guarantees arising from a cast vote of the Federal Government at the...more
The Attorney General's Office of the National Treasury (PGFN) and the Brazilian Internal Revenue Service (IRS) published Public Notices No. 25, 26 and 27/2024, within the scope of the Integral Settlement Program, setting...more
On January 16, 2025, Brazil’s president sanctioned Complementary Law No. 214/2025 (CL 214), stemming from the approval of Complementary Bill of Law No. 68/2024 (PLP 68), which establishes the Tax and Contribution on Goods and...more
In the last week of 2024, the Brazilian Senate approved Supplementary Bill No. 210/2024 (PLP 210/2024), which includes one of the measures in the government’s cost-cutting package....more
With the advance of the regulation of the Tax Reform object of Constitutional Amendment No. 132/2023, the Brazilian Internal Revenue Service (“IRS”) published the Ordinance No. 501/2024 on December 26, 2024, which established...more
BRASIL E CHINA ASSINAM NOVO ACORDO SOBRE VISTOS DE TURISMO E NEGÓCIOS -
O Ministro Mauro Vieira e o Ministro dos Negócios Estrangeiros da República Popular da China, Wang Yi, assinaram na data de 19 de janeiro de 2024, em...more
BRAZIL AND CHINA SIGN TOURISM AND BUSINESS VISA AGREEMENT -
On January 19, 2024, an agreement was signed between Brazil and the People’s Republic of China, doubling the maximum length for tourism and business trips on...more
On August 30, 2024, Ordinance MF No. 1,383 was published, establishing the Full Transaction Program (PTI). The PTI provides a set of measures to reduce federal tax litigation with “high economic impact,” encouraging the...more
With the mid-year recess ending, Brazil’s Superior Courts are preparing to review certain notable tax thesis in the second half of 2024.
Among the tax cases before the Federal Supreme Court (STF), the following stand...more
On August 5, 2024, Brazilian Ministry of Finance (MF) Ordinances No. 1,239 and 1,240/2024 were published in the Federal Official Gazette, providing operating rules for non-concurrent sessions of the Administrative Tax Appeal...more
On July 24, 2024, Normative Instruction No. 2,205/ of the Brazilian Federal Revenue Service (the "Instruction”) was published, that regulates Article 25, paragraph 9-A, and Article 25-A of Decree No. 70,235/1972, establishing...more
In a move to regulate the ancillary obligation created by Provisional Measure No. 1,227/2024, on June 18, 2024, the Brazilian Federal Revenue Service (RFB) published Normative Instruction RFB No. 2,198/2024 (the...more
On May 17, 2024, the Office of the Attorney-General of the National Treasury (“PGFN”) and the Brazilian Internal Revenue Service (“Brazilian IRS”) jointly published the Public Notice of Settlement for Adhesion No. 6/2024...more
On May 16, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) and the Office of Attorney-General of the National Treasury (“PGFN”) jointly published the Public Notice of Transaction for Adhesion in the Tax...more
On May 13, 2024, the Attorney General's Office of the National Treasury published PGDAU Public Notice No. 2/2024, which creates a new tax settlement method for credits enrolled into federal overdue tax liability, with or...more
On April 24, 2024, the Executive Branch introduced Complementary Bill of Law No. 68/2024 ("PLP 68" or the “Bill”), which creates the Tax and the Contribution on Goods and Services ("IBS" and "CBS") as well as the Selective...more
On March 19, 2024, Adhesion Transaction Notice No. 01/2024 (“Zero Litigation Program 2024” or the “Program”) was published, paving the way for tax settlements between taxpayers and the Brazilian Federal Revenue. Through the...more
The Brazilian Tax Reform on consumption was enacted through Complementary Amendment No. 132/2023, which unified the main taxes on the consumption of goods and services in the form of a Dual VAT and through the creation of a...more