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STF's Relevant Tax Decisions of the Week

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

Full Transaction Program Established to Reduce Federal Tax Litigation

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

STF's and STJ's Tax Agenda for the 2nd Half of 2024

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

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

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

Public Notice No. 6/2024: Tax Settlement for Credits Arising from Charter and Services Agreements

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

Public Notice for Adhesion to Tax Settlement: Tax debts Related to Subsidies for Investments

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

PGDAU Public Notice No. 2/2024: New tax settlement program for credits up to 45 million reais enrolled into federal overdue tax...

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

Brazilian Tax Reform: Complementary Bill of Law No. 68/2024

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

Brazilian IRS Program Incentivizes Disclosure of Certain Tax Liabilities

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

Brazil Tax News: Laws, Provisional Measures, Normative Instructions, and Bill of Law Approved at End of December 2023

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

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