News & Analysis as of

Brazil Tax Credits

Mayer Brown

Brazilian Internal Revenue Service Publishes New Rules for Low-Value Debts and Debts Up to BRL 50 Million

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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

Mayer Brown

Direito Tributário em Destaque | Especial Reforma Tributária – Créditos na Transição

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Com a proximidade da implementação das primeiras mudanças da Reforma Tributária, aprovada pela Emenda Constitucional n.º 132/2023, um dos principais temas de interesse dos contribuintes envolve a transição em relação aos...more

Mayer Brown

Brasília em Pauta – Edição Nº 205

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Prezados e prezadas, O “Brasília em Pauta” é um boletim semanal preparado pela equipe de Contencioso de Brasília, contendo os principais casos a serem julgados pelo Supremo Tribunal Federal (STF), Superior Tribunal de...more

Mayer Brown

Superior Court of Justice Changes Understanding on Statute of Limitations for Offsetting Tax Credits Arising from Judicial...

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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

Mayer Brown

STF Establishes Non-Incidence of ISS on Commissioned Manufacturing Activities

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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

Mayer Brown

Brasília em Pauta – Edição Nº 189

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PAUTAS: STF – CONTROLE CONCENTRADO E REPERCUSSÃO GERAL | STJ – REPETITIVOS | TCU – PLENÁRIO | CÂMARA DOS DEPUTADOS | SENADO FEDERAL - Prezados e prezadas, O “Brasília em Pauta” é um boletim semanal preparado pela...more

DLA Piper

Brazil - VAT: Approval of the Supplementary Law on Tax Reform - Monthly Indirect Tax Alert – January 2025

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On 16 January 2025, the President ratified Supplementary Law No. 214/2025, marking a significant step in Brazilian tax reform. This new law outlines the framework for the IBS, the CBS, and IS, while also establishing the IBS...more

Mayer Brown

Federal Taxes Settlement Program – PGFN and RFB Publish Notices on Debt Settlements

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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

Mayer Brown

Brazilian Tax Reform: Complementary Law No. 214/2025 Sanctioned

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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

Mayer Brown

Supplementary Bill No. 210/2024 – Conversion on Supplementary Law No. 211/2024 After Presidential Sanction

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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

Mayer Brown

National Congress Approves Additional CSLL to Adapt to OECD Globe Rules and New Provisions Related to Brazilian Worldwide Taxation...

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I – ADDITIONAL CSLL - Following the House of Representatives’ approval just one day before, the Brazilian Federal Senate approved, on December 18, 2024, Bill of Law No. 3,817/2024 (the “bill”), which introduces an...more

Mayer Brown

STF's Relevant Tax Decisions of the Week

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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

Mayer Brown

Low-Carbon Hydrogen Development Program Sanctioned and Published

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The Brazilian Federal Government has enacted and published Law No. 14.990/2024, which establishes the Low-Carbon Hydrogen Development Program (PHBC), in line with similar international policies such as the US Inflation...more

Mayer Brown

New Trial Method at CARF: Virtual Plenary - MF Ordinances No. 1,239 and 1,240/2024

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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

Mayer Brown

Normative Instruction RFB No. 2,205/2024: Regulation of the Effects Applicable to Cases Decided by CARF by Casting Vote

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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

Mayer Brown

Brazilian Federal Revenue Establishes Rules for New ‘DIRBI' Tax Return

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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

Mayer Brown

Tax Settlement Adhesion Notice No. 01/2024: Zero Litigation Program 2024

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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

Mayer Brown

Brazilian IRS Clarifies Taxation of Credits Originated from a Court Decision

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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

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