Brazil Clarifies Pillar Two Reporting for CSLL Surcharge
The Brazilian Federal Revenue Service (RFB) has designated DCTFWeb as the filing channel for reporting the Brazilian QDMTT (Brazil’s domestic top-up tax under Pillar Two). Taxpayers must report these amounts by the end of June 2026, with payment expected to be due by the last business day of July 2026. Despite this formalization, technical gaps […]
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 […]
New Law on Income and Dividend Taxation: Impacts on Non-Residents and Cross-Border Remittances
The new Brazilian income tax law is now in force, effectively reinstating the withholding tax (WHT) on dividend distributions, including all remittances abroad. This measure, long anticipated by the market, significantly impacts non-resident investors and multinational structures. Our team has prepared a complete e-book with details about the new legislation.
M&A Activity in Brazil Rebounds, Technology Leads 2025 Deal Volume
The Brazilian mergers and acquisitions (M&A) market experienced a robust rebound in 2025. Despite facing persistent global headwinds, the market has demonstrated resilience and continued to expand its deal volume, reinforcing Brazil’s leading position in Latin America. According to TTR Data Brazil (TTR), Brazil recorded about 1,142 transactions totaling roughly BRL 187.8 billion through August […]
REDATA – Special Regime for Data Centers Established by Interim Measure 1,318/2025
On September 18, 2025, the Federal Government issued Interim Measure (MP) No. 1,318/2025 in the Federal Official Gazette, creating the Special Tax Regime for Data Center Services (REDATA). The goal is to encourage the installation, expansion, and modernization of Brazil’s digital infrastructure, fostering innovation, cost reductions, and stronger digital sovereignty. The measure amends Law No. […]