Tax Clipping | Stay Up to Date with the Highlights

In this edition of the BVZ Tax Clipping, we bring together updates on the implementation of Tax Reform, new tax settlement arrangements and recent decisions involving federal, state and municipal taxes.

Check out the highlights of this edition:

Tax Reform
– Paraná’s Finance Department states that IBS and CBS will be included in the ICMS tax base as of 2027.
– A Joint Ordinance establishes the methodology for calculating IBS and CBS rates on fuels.
– CGIBS and the Brazilian Federal Revenue Service publish new technical documentation and the DeRE User Manual.

Tax Settlements
– The Brazilian Federal Revenue Service and the Attorney General’s Office of the National Treasury (PGFN) open negotiations for debts related to fines replacing the penalty of forfeiture, with applications accepted until 29 December.
– PGFN launches notices for the renegotiation of debts owed by individual microentrepreneurs (MEIs) and employers, and extends the deadlines for previous programmes.

Tax Updates
– The Brazilian Federal Revenue Service incorporates an OECD simplification rule for tax incentives into the calculation of the Additional CSLL.
– The 2026 Letters Project encourages voluntary correction of individual income tax (IRPF) returns retained for further review.
– The Brazilian Supreme Federal Court (STF) rules that presumed ICMS tax credits must be excluded from the PIS and Cofins tax bases.
– The STF establishes criteria for imposing fines on companies that distribute profits while having outstanding tax liabilities.
– The Administrative Council of Tax Appeals (CARF) rules that transfers from the Energy Development Account (CDE) are included in the PIS and Cofins tax bases.
– The Federal Court in São Paulo rules against the withholding of 10% income tax on dividends due to the absence of a transitional tax bracket.
– The STF upholds the decree that updated the property tax (IPTU) assessment base in Bragança Paulista, São Paulo.

Access the full edition for more information.