Tax Clipping | Stay Up to Date with the Highlights

The latest edition of the Tax Clipping brings together key regulatory, administrative, and judicial developments with a direct impact on tax compliance, litigation, and decision-making.

Among the week’s highlights:

Tax Reform
– Supplementary Law No. 227/2026 introduces a hybrid system for counting procedural deadlines in tax administrative proceedings, combining business days and calendar days, already incorporating guidelines from the future IBS Management Committee.
– The IBS Pre-Management Committee released the 2nd updated edition of the Guidance Manual on the Administrative Impacts of the Tax Reform, providing technical guidelines for states and municipalities in adapting to the new system.

Tax Settlements
– Individual microentrepreneurs (MEIs), micro and small companies have until January 30 to adhere to special settlement programs for federal tax debts enrolled in federal tax debt collection, offering significant discounts and extended installment options.

Tax Updates
– The Brazilian Federal Revenue Service has made the Electronic Tax Domicile (DTE) mandatory for all legal entities as of 2026, consolidating it as the official channel for tax communications.
– The Declaration of Option for the Special Regime for Asset Regularization (DERP) has been made available, enabling adherence to REARP until February 2026.
– CARF recognized that disproportionate profit distributions do not prevent withholding income tax exemption when supported by proper accounting records and contractual provisions.
– The Brazilian Federal Revenue Service clarified the application of the deemed profit margin of 32% to speech therapy services under the presumed profit regime.
– Federal Regional Courts have allowed refund via court-ordered payments (precatórios) of credits arising from the “thesis of the century,” even when initially submitted for administrative offset.

We continue to closely monitor the developments shaping the Brazilian tax environment and directly impacting tax planning and litigation strategies in 2026.

Access the full edition for more information.