LC 224/2025: Reduction of Tax Incentives and Increase in the Tax Burden
A recent Complementary Law introduces a 10% reduction across various federal tax incentives, effective as of 2026. The legislation also restricts the attractiveness of the presumed profit regime for larger companies, increases taxation on Interest on Net Equity (JCP), and imposes structural constraints on the future expansion of tax benefits, resulting in a significantly higher […]
São Paulo Court Upholds Fiduciary Security, Barring Refund Claims by Defaulting Buyers
The São Paulo State Court of Justice (TJSP) has reaffirmed the strength of fiduciary transfer of title in real estate transactions. In a recent ruling, the Court denied a defaulting buyer’s attempt to terminate a purchase agreement and recover previously paid amounts, prioritizing specialized real estate financing laws over general consumer protection rules. Prevalence of Special Legislation […]
NR-01: Mental Health and Psychosocial Risk Enforcement to Begin on 26 May 2026
Work place mental health has moved to the forefront of Brazil’s regulatory agenda. Effective 26 May 2026, the amended Regulatory Standard No. 1 (NR-01) – as established by MTE Ordinance No. 765/2025 – will require companies to integrate psychosocial risk management, including mental health as part of harassment-prevention measures, into their mandatory Risk Management Programs (PGR). Key Compliance Requirements The new […]
STF Confirms STJ Approach and Shifts Stock Option Taxation to Share Sale
Brazil’s Supreme Federal Court (STF) has issued a decision declining to hear constitutional claims concerning the taxation of stock option plans. By holding that the issue is not constitutional in nature, the STF effectively cemented the Superior Court of Justice’s (STJ) taxpayer-friendly precedent (Theme 1,226), confirming that qualifying stock option plans are commercial contracts – not […]
Brazil Enhances Beneficial Ownership (UBO) Reporting Requirements
Effective as of 1 January 2026, Brazil has updated its UBO reporting framework, introducing a new digital filing tool – the e-BEF (Digital Beneficial Ownership Form) – to streamline compliance with the Brazilian Federal Revenue Service reporting requirements. Since 2016, both Brazilian and foreign entities have been required to disclose their ultimate beneficial owners. Non-compliance may result in the suspension of […]
ICMS Exemption for Sales to Free Trade Areas (FTAs)
São Paulo State Decree No. 70,348/2026 introduces a temporary ICMS exemption for sales of domestic industrialized or semi-finished goods to specific Free Trade Areas (FTAs). The measure is retroactive to 29 December 2025 and remains effective until 30 September 2026. Scope and Eligibility The exemption applies to sales destined for resale or industrial processing by […]
Brazilian Government Expands Taxation Through Interim Measure and Revises IOF Rates by Decree
On 22 May 2025, the Brazilian Government issued Decree 12,466/2025, raising the rate of the Tax on Financial Transactions (IOF) to increase federal revenue. Among the key changes, the government introduced a 3.5% IOF rate on investments made abroad by Brazilian investment funds, which had previously been exempt. Additionally, the IOF rate on cash foreign […]