Brazil implements global rules against base erosion (globe rules) through interim measure 1,262/2024
On 3 October 2024, the Brazilian government issued Interim Measure 1,262, introducing significant changes to the country’s tax system by establishing an Additional Social Contribution on Net Profit (CSLL) to ensure an effective minimum tax rate of 15%. This measure integrates Brazil’s tax policies with international anti-erosion standards (GloBE Rules), developed under the Inclusive Framework […]
Favorable ‘CARF’ decision on PIS/Cofins credits for imported inputs
In a recent ruling, the 3rd Panel of the Superior Chamber of the Administrative Council of Tax Appeals (CARF) unanimously recognized the right to claim PIS (Social Integration Program) and COFINS (Contribution for the Financing of Social Security) credits on freight expenses for imported inputs used in production. The decision was issued in administrative cases […]
Moral damages for unauthorized use of sensitive employee data
Under items I and II of Article 6 of the General Data Protection Law (LGPD – Law No. 13,709/2018), individuals or entities holding personal data must process it in good faith for legitimate, specific, and informed purposes communicated to the data subject. Article 5, item LXXIX of the Federal Constitution supports this provision, which guarantees, […]
‘ADIs’ 6,040 and 6,055: Possibility of reducing the ‘reintegra’ rate and the respective residual credit
By a seven-to-two vote, the Federal Supreme Court (the STF) confirmed that the Executive Branch can freely adjust rates under the Special Regime for the Reinstatement of Tax Values for Exporting Companies (Reintegra). The established thesis is as follows: “Article 22 of Law No. 13,043/2014, which authorizes the Federal Executive Branch to determine the percentage […]
‘CVM’ Resolution 215: Changes to public tender offer regulations
CVM Resolution 215, issued in October 2024 by the Brazilian Securities and Exchange Commission (CVM), introduced significant updates to Public Tender Offer (PTO) regulations. These adjustments align the Brazilian market with international practices while balancing market demands and investor protection. Additionally, they simplify and streamline the process. A PTO is a mechanism through which companies […]
New ‘Sisbajud’ regulations: Tackling fraud and locating ‘front persons’
The National Justice Council (CNJ) established a new regulatory framework for the Judiciary’s Asset Search System (Sisbajud) through Ordinance 03/2024. This new regulation aims to improve efficiency and security in asset identification and freezing, while intensifying the fight against asset fraud. The key points are as follows: (i) Detection of Front Persons and Asset Concealment […]