Consumption Tax Reform pilot program: Contribution on Goods and Services systems now in use at 500 Brazilian companies
Brazil’s tax reform took a concrete step toward implementation. As of 1 July 2025, the Consumption Tax Reform pilot program is in effect under RFB Administrative Ordinance 549, dated 13 June 2025. This initial phase is designed to validate systems and processes for the new Contribution on Goods and Services (CBS) and gives companies an […]
Brazil’s Tax Reform: implications for M&A transactions
Following Constitutional Amendment 132/2023, Brazil launched a tax reform that will extinguish four taxes – State Value-Added Tax on Goods and Services (ICMS), Municipal Service Tax (ISS), Social Integration Program contribution (PIS), and Contribution for the Financing of Social Security (COFINS). They will be replaced by the Contribution on Goods and Services (CBS) and the […]
Brazilian Federal Revenue Service Tax Settlements: a strategic opportunity for companies
Created by Law 13,988/2020, Tax Settlement allows taxpayers negotiate tax liabilities, resolve disputes with the tax authorities, and reach faster, more predictable outcomes. Its use at the Brazilian Federal Revenue Service (RFB) has expanded in recent years; according to the 2025 “PGFN in Numbers” report from the Office of the Attorney General of the National […]
Brazilian Federal Revenue Service narrows the base for calculating Interest on Equity by subordinate regulation
The Brazilian Federal Revenue Service (RFB) issued Tax Directive 2,201/24 to implement the new rules on Interest on Equity (JCP) introduced by Law 14,789/23 (Subsidies Law). The Directive identifies which shareholders’ equity accounts may, or may not, be used to calculate JCP. Interest on Equity is a form of shareholder remuneration available to companies taxed […]
São Paulo State Announces Emergency Measures to Offset Impact of U.S. Tariffs on Brazilian Exports
Following new U.S. tariffs on goods imported from Brazil, several Brazilian states are implementing fiscal measures to cushion export-oriented companies. On 7 May 2025, governors from ten Brazilian states—São Paulo, Minas Gerais, Rio de Janeiro, Paraná, Santa Catarina, Rio Grande do Sul, Goiás, Mato Grosso, Amazonas, and the Federal District—met to assess the economic impact […]
Countermeasures Law: Government Issues Decree Regulating Retaliatory Framework
On 15 July 2025, the Brazilian Federal Government published Decree No. 12,551/25 in the Official Gazette. The decree implements the Countermeasures Law, enacted in April 2025, which authorizes suspending trade, investment, and intellectual property concessions in response to unilateral measures adopted by foreign countries or economic blocs. The decree was issued in the context of […]
International Personal Data Transfers: Deadline for Compliance Due August 2025
Data controllers and processors in Brazil must update contracts by August 2025 to include the standard clauses for international personal data transfers under ANPD (Brazilian Data Protection Authority) Directive No. 19/2024. These transfers occur when an exporter in Brazil sends, shares, or provides access to personal data collected locally to an importer abroad, such as […]
STF Redefines the Liability of Digital Platforms: Impacts and New Obligations
On June 26, 2025, the Brazilian Federal Supreme Court (STF) declared Article 19 of the Brazilian Internet Civil Framework (Law No. 12,965/2014) partially unconstitutional, establishing new parameters for the civil liability of digital platforms for third-party content. By majority vote, the Court ruled that requiring a judicial order as a prior and absolute condition for […]
Congress Overturns IOF Increase
On 25 June 2025, Brazil’s National Congress passed Draft Legislative Decree (PDL) No. 214/2025, suspending Federal Decrees 12,466/2025, 12,467/2025, and 12,499/2025, which increased the Tax on Financial Transactions (IOF) rates. As a result, all three decrees have been repealed. Read more: Brazilian Government Expands Taxation Through Interim Measure and Revises IOF Rates by Decree The […]
New tax framework to impact operational, contractual, and accounting flows
Brazil’s new tax framework, established by Supplementary Law No. 214/2025, represents a comprehensive overhaul of the country’s tax system. The reform introduces structural changes that significantly affect consumption taxes—including PIS, Cofins, ICMS, ISS, and IPI—and ongoing discussions on corporate income taxation (IRPJ and CSLL). Although full implementation is scheduled for 2033, the transition has already […]