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 ,
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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
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
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
On December 21, 2023, the Brazilian Federal Revenue enacted Normative Instruction No. 2,167/2023 ("the Instruction"), which was published in the Federal Official Gazette. The Instruction provides rules for the standardization...more
After more than two decades of discussions, the National Congress approved, and the President of the Republic enacted the final text of the Constitutional Amendment n. 132/2023, known as the Brazilian Tax Reform on...more