Tax Clipping | Stay Up to Date with the Highlights

The latest edition of our Tax Clipping brings together the week’s key developments with a direct impact on compliance, tax litigation, tax planning, and the transition to the new consumption tax model.

Among the highlights:

Tax Reform
– The São Paulo State Department of Finance (Sefaz-SP) reaffirmed that the IBS and CBS will be included in the ICMS tax base as of 2027, during the period in which the taxes will coexist.
– The EFD-Contributions filing obligation will remain in force until the end of 2026 and must continue to be maintained for the control and offsetting of PIS and Cofins credits after the CBS comes into effect.

Tax Regularization (Tax Settlements and Installment Programs)
– The Brazilian Federal Revenue Service redesigned its Tax Settlement webpage, introducing more intuitive navigation, a comparative overview of public notices, and the prospect of new digital features.
– The Municipality of São Paulo has reopened its Active Debt regularization program, offering discounts of up to 95% on interest and penalties, as well as installment payment options of up to 120 months.

Tax Updates
– The Brazilian Federal Revenue Service published a Questions and Answers guide regarding Supplementary Law No. 227/2026 and issued transitional rules governing the calculation of procedural deadlines in administrative tax litigation.
– Relevant administrative interpretations continue to evolve regarding PIS/Cofins on imports through leasing arrangements, the incidence of withholding income tax (IRRF) on income from Real Estate Investment Funds (FIIs), and CIDE on remittances related to the App Store.
– The Brazilian Federal Revenue Service has summoned legal entities with omissions in ancillary obligations, warning of the risks of CNPJ suspension and other restrictions.
– CARF reaffirmed that bookkeeping records in SPED do not, by themselves, constitute a tax credit.

We continue to closely monitor the regulatory, administrative, and judicial developments shaping the Brazilian tax landscape in 2026 and directly impacting corporate decision-making.

Access the full edition for more information.