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
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
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 ,
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State and Local Government ,
State Taxes ,
Tax Credits ,
Tax Planning ,
Tax Reform ,
Taxation
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
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 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
On December 19, 2023, the Brazilian IRS published COSIT Answer to Advance Tax Ruling Request No. 308/2023 to clarify the Federal Tax Administration’s position regarding the levy of IRPJ, CSLL, PIS and COFINS on credits...more