
The past week brought significant developments in the implementation agenda of the Tax Reform, as well as institutional initiatives and administrative decisions with a direct impact on ancillary obligations, tax structuring, and strategies for the regularization of tax liabilities.
In this edition, we have gathered the key points requiring strategic attention:
Tax Reform
– The IBS secondary regulation is expected to be presented by April 15, with alignment to the CBS framework and technical divergences still under discussion.
– The Brazilian Federal Revenue Service confirmed a testing period in 2026, with no penalties to be imposed until 90 days after the issuance of the relevant regulations.
Tax Settlements
– The Office of the Attorney General of the Union (AGU) regulated new tax settlement modalities, providing broader discounts and extended deadlines for the negotiation of federal debts.
Tax Updates
– The Brazilian Federal Revenue Service made available a new version of the DCTF Filing Program (PGD DCTF), including adjustments to the MAED.
– The State of São Paulo now requires the indication of the tax benefit code (cBenef) in electronic invoices.
– CARF upheld the deductibility of interest expenses on loans obtained for the payment of dividends.
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