Martinelli Updates

Brazilian Federal Revenue Service narrows the base for calculating Interest on Equity by subordinate regulation

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Economic Reciprocity Law

The Economic Reciprocity Law (Law No. 15,122/2025) was enacted by the Brazilian Federal Government without vetoes and published in the Official Gazette. The law provides legal tools that allow Brazil to adopt trade countermeasures in response to unilateral actions by foreign countries or economic blocs, based on criteria set forth in the law itself.

This follows the United States’ announcement of a 10% across-the-board tariff on Brazilian exports, along with an additional 25% tariff on steel and aluminium — a sector in which Brazil is currently the third-largest exporter to the US market. The publication comes amid escalating tariff tensions triggered by the US as part of its strategy to rebuild domestic industrial capacity, focusing on strategic sectors such as semiconductors and clean energy, with the primary aim of curbing China’s technological and commercial expansion.

Under the new legislation, the President is authorised to adopt proportional countermeasures — such as import restrictions, suspension of concessions, and suspension of treaty obligations, including those related to intellectual property — whenever Brazil suffers concrete harm. Implementation will depend on the government’s own assessment and justification.

The law also allows sanctions in cases where environmental regulations cause damage to, or override, Brazilian standards. This measure responds to the European Union Regulation on Deforestation-Free Products (EU Anti-Deforestation Law), adopted on 31 May 2023 as part of the European Green Deal. The response stems from the fact that international legislation imposes stricter requirements than those currently in force in Brazil.

The new law introduces a new dynamic in Brazil’s international economic relations, with potential impacts on trade and investment flows. Although its implementation still requires regulation, companies integrated into global value chains should closely monitor developments in Brazil’s trade policy under this new legal framework.

Breno Consoli

Ettore Botteselli

Roberto Hering Meyer

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