Tax Clipping | Stay Up to Date with the Highlights

In this edition of the BVZ Tax Clipping, we bring together relevant updates on the implementation of the Tax Reform, new tax settlement rules, and recent decisions involving tax benefits, corporate income tax (IRPJ), PIS/Cofins, export tax, and ITBI.

Check out the highlights of this edition:

Tax Reform
– The Brazilian Federal Revenue Service opens the period for opting into the Simples Nacional tax regime and for choosing the collection model for IBS and CBS in 2027.
– The Management Committee of the Goods and Services Tax (CGIBS) and the Brazilian Federal Revenue Service clarify the deadlines for complying with obligations related to the Special Regime Statement (DeRE), including guidance on the first monthly tax and accounting filing.

Tax Settlement
– The Federal Court rules against counting the waiting period for entering into a new tax settlement from the administrative formalization of the termination, considering instead the effective date of default.

Tax Updates
– The Brazilian Federal Revenue Service enhances the rules for monitoring the use of tax incentives, waivers, and benefits.
– The Superior Court of Justice (STJ) rules that corporate income tax (IRPJ) applies to capital gains earned by real estate investment funds from transactions involving shares of other funds.
– The Superior Court of Justice (STJ) recognizes the right to PIS/Cofins tax credits on gasoline and diesel used as inputs in the formulation of new products.
– The Federal Court of the Federal District grants an injunction suspending the collection of Export Tax on crude oil.
– The Federal Supreme Court (STF) resumes the trial concerning ITBI immunity on the contribution of capital through the transfer of real estate to companies in the real estate sector.
– The São Paulo State Court of Appeals (TJSP) rules that ITBI does not apply to real estate transferred as part of a full corporate merger.

Access the full edition for more information.