Tax Clipping | Stay Up to Date with the Highlights

In this edition of the BVZ Tax Newsletter, we bring together relevant updates on the implementation of the Tax Reform, tax settlements and installment plans, as well as recent decisions involving DeRE, split payment, tax enforcement, ITR, judicial reorganization, ITCMD and ITBI.

Check out the highlights of this edition:

Tax Reform
– The CGIBS and the Brazilian Federal Revenue Service clarify the deadlines for complying with obligations related to the Special Regime Declaration (DeRE), including the submission of table events and the first monthly accounting and tax filing.
– Technical Bulletin 2026.001 standardizes payment method codes in Electronic Tax Documents, in preparation for the implementation of split payment.

Tax Settlement/Installment Plans
– The STJ upholds the right to use tax credits arising from a court decision to settle tax debts under installment plans or registered as tax liabilities.
– The STJ rules that tax loss credits and negative CSLL calculation basis credits belonging to a company may not be used by an individual shareholder to settle their own debt under the Special Tax Regularization Program (Pert).

Tax Updates
– The STJ rules that redirecting tax enforcement proceedings against an estate or successors depends on the debtor having been served before their death.
– Carf upholds the assessment of ITR on rural property occupied by landless workers.
– The STF upholds restrictions on access to judicial reorganization proceedings by persistent tax debtors.
– The CNJ approves a change waiving the requirement for advance payment of ITCMD for the purpose of conducting extrajudicial probate proceedings.
– The São Paulo Court of Justice (TJSP) rules out the levy of ITBI on the difference in the value of a property used to contribute capital to a company.

Access the full edition for more information.