On January 9, 2026, the final text of the Supplementary Law ("LC") No. 225/2026 was published in the Official Gazette of the Federal Government, which launches the Taxpayers´ Defense Code (the “Code”), establishing...more
1/22/2026
/ Brazil ,
Enforcement ,
Enforcement Actions ,
New Legislation ,
Penalties ,
Tax Audits ,
Tax Evasion ,
Tax Fraud ,
Tax Legislation ,
Tax Liability ,
Tax Reform ,
Taxation ,
Transfer Pricing
On December 9, 2025, Decree No. 50.040/2025 was published in the Official Gazette of the State of Rio de Janeiro (“DOERJ”). The decree regulates the special program (the “Program”) allowing for payment in installments of tax...more
On November 26, 2025, Bill No. 1,087/2025 (“Bill No. 1,087”) was enacted and converted into Law No. 15,270/2025, which introduces a series of relevant changes to income taxation, including:
expansion of the exemption...more
UPDATES IN EVIDENCE:
Bill No. 1,087/2025 (PL No. 1,087/2025) proposes a reform of the Income Tax system, with the goal of making it more just and progressive....more
On October 27, 2025, Complementary Law No. 225/2025 was published in the Official Gazette of the State of Rio de Janeiro , establishing the special installment payment program (the “Program”) for state tax credits, in line...more
On September 1, 2025, the Public Notices PGFN/RFB No. 58 and 59/2025 were published in the Official Gazette of the Union (DOU), authorizing taxpayers to join the settlement program for credits arising from tax litigation...more
On August 22, 2025, the Brazilian Supreme Court (STF) concluded the trial related to Theme 1367 (leading case RE No. 1,490,708). The STF ruled, in the context of motion to clarify, that retroactive collection of ICMS is...more
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
/ Brazil ,
Constitutional Challenges ,
Corporate Taxes ,
Manufacturers ,
Regulatory Reform ,
Regulatory Requirements ,
State and Local Government ,
State Taxes ,
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
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