On May 22, 2025, Decree No. 12,466 was published, increasing the tax rates of Tax on Financial Transactions (“IOF”) levied on multiple operations of insurance, credit and exchange, especially the ones related to (i) credits...more
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 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 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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Regulatory Reform ,
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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
Last week, the Brazilian Supreme Court (STF) issued decisions on two relevant tax issues: (i) the effective reduction in percentage of the amounts reimbursed to exporters under the Special Regime for the Reintegration of Tax...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 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
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 April 3, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) published Normative Instruction RFB No. 2,184 (“IN/RFB No. 2,184/2024“), regulating a special program to incentivize the voluntary disclosure of...more
Several new rules were approved on December 28, 2023, all extremely relevant to tax law. Our tax team summarizes some of the more relevant new rules...more