Tax Clipping | Stay Up to Date with the Highlights

The latest edition of the BVZ Tax Clipping brings together the main developments in the Tax Reform, updates on tax settlements, and significant rulings by the higher courts with implications for businesses and taxpayers.

Among this week’s highlights:

Tax Reform

– The Brazilian Federal Revenue Service published a Technical Note establishing new rules for electronic tax documents, including requirements related to the IBS, CBS, cashback mechanisms, and validation adjustments.
– The IBS Management Committee expanded the pilot phase of the IBS assessment system, which now includes the participation of 90 companies.
– The Brazilian Federal Revenue Service confirmed the preservation of accumulated PIS/Cofins tax credits during the transition to the CBS, scheduled for 2027.
– The Brazilian Federal Revenue Service and the IBS Management Committee authorized the publication of the Integration Manual and the Swagger documentation for the Public Split Payment Platform.
– The Brazilian Federal Revenue Service updated its transparency rules regarding tax incentives and benefits, expanding the use of DIRBI.

Tax Settlements

– The Office of the Attorney-General of the National Treasury (PGFN) published a new notice for the negotiation of tax debts enrolled in the active debt registry of up to BRL 45 million, with applications open until September 30, 2026.

Tax Updates

– The Federal Regional Court of the 3rd Region (TRF3) suspended the 10% surcharge on IRPJ and CSLL for a company under the presumed profit regime.
– The Superior Court of Justice (STJ) declined, for the time being, to apply the repetitive appeals procedure to the discussion concerning the tax amortization of internal goodwill involving a special-purpose vehicle.
– The STJ upheld the modulation of effects under Theme 1,079, preserving the right to recover amounts paid to the “Sistema S” entities in certain circumstances.
– The Brazilian Federal Revenue Service released version 12.1.6 of the Corporate Tax Accounting Bookkeeping (ECF) program.
– The Chamber of Deputies approved a Constitutional Amendment Proposal (PEC) expanding tax immunity for churches and affiliated entities, with potential impacts on the revenue generated by the new consumption taxes.

We continue to monitor the regulatory, administrative, and judicial developments that impact business decision-making in 2026.

Access the full edition for more information.