
In this edition of the BVZ Tax Newsletter, we have gathered relevant updates on the implementation of the Tax Reform, the operation of split payment, rules applicable to the Simples Nacional and cooperatives, as well as recent decisions and measures in tax matters.
Check out the highlights of this edition:
Tax Reform
– The Brazilian Federal Revenue Service and the IBS Management Committee (CGIBS) approve technical documents for the implementation of split payment.
– Nearly 120,000 applications to opt for Simples Nacional in 2027 were initially denied but can still be regularized.
– Cooperatives may opt for the specific IBS and CBS regime until October 31, with effects as of January 2027.
Tax Updates
– The Brazilian Federal Revenue Service opens consultation for the 2026 residual individual income tax refund batch, with 412,186 refunds.
– The Brazilian Federal Revenue Service incorporates an OECD rule on tax incentives for multinational companies.
– The Brazilian Federal Revenue Service extends a transition rule that may reduce the Additional CSLL for multinational companies to zero through 2027.
– São Paulo will begin issuing a Single Tax Debt Clearance Certificate as of October.
– The Brazilian Supreme Court (STF) upholds a monthly limitation on the offsetting of tax credits exceeding BRL 10 million.
– CARF rules out the application of an intercurring statute of limitations in a case involving fraudulent intermediation.
– CARF approves eight new precedents on Cide, IOF, Senar, IPI, IRPJ, CSLL and other matters.
– The Federal Court of São Paulo considers the fixed 10% withholding income tax on profits and dividends unconstitutional.
– The STF reaches a majority against including subsidies related to the social electricity tariff in the ICMS tax base.
– The Court of Justice of Minas Gerais (TJ/MG) authorizes the release of contractual attorneys’ fees from a court-ordered debt while the applicability of ITCD is under discussion.
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