International Personal Data Transfers: Deadline for Compliance Due August 2025
Data controllers and processors in Brazil must update contracts by August 2025 to include the standard clauses for international personal data transfers under ANPD (Brazilian Data Protection Authority) Directive No. 19/2024. These transfers occur when an exporter in Brazil sends, shares, or provides access to personal data collected locally to an importer abroad, such as […]
STF Redefines the Liability of Digital Platforms: Impacts and New Obligations
On June 26, 2025, the Brazilian Federal Supreme Court (STF) declared Article 19 of the Brazilian Internet Civil Framework (Law No. 12,965/2014) partially unconstitutional, establishing new parameters for the civil liability of digital platforms for third-party content. By majority vote, the Court ruled that requiring a judicial order as a prior and absolute condition for […]
Congress Overturns IOF Increase
On 25 June 2025, Brazil’s National Congress passed Draft Legislative Decree (PDL) No. 214/2025, suspending Federal Decrees 12,466/2025, 12,467/2025, and 12,499/2025, which increased the Tax on Financial Transactions (IOF) rates. As a result, all three decrees have been repealed. Read more: Brazilian Government Expands Taxation Through Interim Measure and Revises IOF Rates by Decree The […]
New tax framework to impact operational, contractual, and accounting flows
Brazil’s new tax framework, established by Supplementary Law No. 214/2025, represents a comprehensive overhaul of the country’s tax system. The reform introduces structural changes that significantly affect consumption taxes—including PIS, Cofins, ICMS, ISS, and IPI—and ongoing discussions on corporate income taxation (IRPJ and CSLL). Although full implementation is scheduled for 2033, the transition has already […]
Brazil updates PIS and Cofins rules to strengthen legal certainty
Brazilian Federal Revenue Service Tax Directive No. 2,264, issued on 30 April 2025, updates and amends provisions of Tax Directive No. 2,121/2022, which consolidates the rules on calculation, collection, audit, enforcement, and administration of PIS and Cofins contributions. The new directive introduces important regulatory developments aimed at aligning administrative regulations with the case law of […]
Brazil confirms reduced withholding tax on royalties under Brazil–France treaty
On 25 March 2025, the Brazilian Federal Revenue Service issued Cosit Ruling No. 54/2025, clarifying that payments made by a Brazilian company to its French-based parent company for software licensing should be classified as royalties and subject to a 10% withholding income tax (IRRF) rate. This reduced rate applies under the Brazil–France Double Taxation Treaty, […]
Disregarded Entities: Brazilian Federal revenue service targets structures like U.S. LLCs and reinforces tax compliance
A widely used corporate structure in the United States for tax efficiency purposes can expose Brazilian companies to tax infraction risks if not properly understood: the disregarded entity. Although fully recognized under U.S. law, it is often viewed more conservatively by the Brazilian Federal Revenue Service (RFB). This calls for heightened attention from Brazilian companies […]
Regulatory changes to public tender offers boost M&A activity in Brazil
In late 2024, the Brazilian Securities and Exchange Commission (CVM) issued Resolution No. 215, set to take effect on 1 July 2025. The new rule updates the regulatory framework for Public Tender Offers (OPAs), balancing market needs with investor protection while simplifying the overall process. A Public Tender Offer allows investors or companies to acquire […]
How Tax Reform is reshaping private contracts
While tax reform is often viewed solely through a fiscal lens, its effects extend into other areas of law. Supplementary Law No. 214/2025 significantly restructures the revenue system, altering the economic foundations of many contracts drafted under the previous tax model. This shift has direct implications for Contract Law. Although it is not yet time […]
Supreme Court to rule on legality of independent contractor model known as “Pejotização”
Brazil’s Federal Supreme Court (STF) will soon decide a key issue for the labor market: the legality of hiring professionals as independent contractors through their own legal entities—a widespread practice known locally as “pejotização.” Under this arrangement, workers provide services as legal entities (PJs), issuing invoices instead of holding formal employment governed by the Consolidation […]