Tax Clipping | Stay Up to Date with the Highlights

The new edition of the BVZ Tax Bulletin brings together key developments regarding Tax Reform, tax settlements, and administrative and judicial updates affecting companies, taxpayers, and wealth structures:

Tax Reform
– The issuance of CNPJ registration numbers and tax documents by individuals subject to the CBS will become effective on January 1, 2027.
– The Federal Accounting Council clarifies that IBS and CBS amounts are not included in companies’ revenue.

Tax Settlement
– The Brazilian Federal Revenue Service has published new tax settlement notices for the negotiation of tax debts under administrative litigation.
– The Office of the National Treasury Attorney-General (PGFN) has regulated the settlement of debts enrolled as active debt related to the FGTS and social security contributions.
– The Superior Court of Justice (STJ) ruled that the write-off of tax loss carryforwards and the negative CSLL tax base must occur before joining a tax settlement program.

Tax Updates
– The Brazilian Federal Revenue Service will make the 2026 DITR available in a web-based version.
– The Brazilian Federal Revenue Service clarifies the taxation of income tax on additional installments arising from the sale of an equity interest.
– The STJ recognizes that an estate may seek the refund of income tax not claimed by the deceased during their lifetime.
– The statute of limitations for administrative inactivity (prescrição intercorrente) before the CARF may lead to the annulment of a customs penalty.