SAO PAULO - ICMS - Special Installment Program (PEP)

The press has recently reported that decisions favorable to taxpayers, rendered in tax administrative proceedings by the Administrative Council of Tax Appeals, have been challenged before the Judiciary through Citizen Suits filed based on Law no. 4,717/65.

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Brazil's Executive Management Committee of the Foreign Trade Chamber has extended the 12% export tax rate on crude petroleum oils and bituminous mineral oils for an additional 60 days. The extension, formalized through GECEX Resolution No. 957/2026, maintains the tax structure previously established under Resolution No. 938/2026 and takes effect on September 8, 2026.

Brazil's Supplementary Law No. 236/2026 introduces sweeping reforms to the Brazilian Tax Code, establishing new caps on tax penalties, expanding taxpayer safeguards during audits and collection proceedings, and incorporating alternative dispute resolution mechanisms including arbitration and mediation. The legislation mandates state and local governments to align their tax procedures with these new national standards within two years or face automatic application of federal provisions.

A Lei Complementar nº 236/2026 introduz mudanças significativas no Código Tributário Nacional, estabelecendo novos limites para multas tributárias, ampliando garantias dos contribuintes e uniformizando procedimentos administrativos fiscais em todo o Brasil. As alterações incluem vinculação da administração a decisões judiciais, redução de penalidades em diversas situações e padronização de prazos processuais.

Brazil's Tax Reform introduces a complex framework of IBS and CBS regulations specifically designed to preserve the Manaus Free Trade Zone's competitive advantage through strategic IPI maintenance, zero-rating mechanisms, and deemed tax credit systems. Companies operating in the Manaus Industrial Pole must navigate new rules governing product classifications, import suspensions converted to exemptions, and intricate credit appropriation requirements that fundamentally reshape regional tax incentives.

A Receita Federal estabeleceu procedimentos distintos para retenção e recolhimento de 10% de IRRF sobre lucros e dividendos distribuídos por pessoas jurídicas brasileiras, diferenciando tratamento entre não residentes e pessoas físicas residentes com pagamentos superiores a R$50 mil mensais. A orientação detalha códigos de receita, prazos de vencimento e procedimentos específicos para cada categoria de beneficiário.

Brazil's Federal Revenue Service has introduced new monitoring procedures that will require legal entities to meet specific compliance criteria to maintain their tax benefits and incentives. Companies must satisfy requirements including federal tax regularity, absence of administrative sanctions, and proper registration, with automated periodic verification beginning September 1, 2026, and a 20-business-day correction window for identified irregularities.

On March 12, 2026, the Brazilian Federal Government announced a package of measures aimed at curbing the increase in fuel prices in the country. Among the initiatives announced, the following stand out...

Brazil's Executive Management Committee of the Chamber of Foreign Trade has issued GECEX Resolution No. 938/2026, establishing a 12% export tax rate on crude petroleum oils for a 60-day period following the expiry of Provisional Measure No. 1,340/2026. The resolution addresses the regulatory gap created when the provisional measure failed to be converted into law within the constitutional timeframe, reinstating export tax provisions on products classified under NCM heading 2709.

Climate disclosure regulations are among the most significant and complex challenges faced by companies and boards, with a variety of requirements emanating this year from numerous governmental authorities...

The Trump Administration has launched an unprecedented enforcement action suspending permanent labor certification processing for eight major employers, linking immigration sponsorship to layoff histories and recruitment practices. This development signals a fundamental shift in how the government evaluates employer access to H-1B and green card programs, with investigations already underway and subpoenas served.

The Department of Energy has launched a rulemaking process to implement new restrictions on foreign-sourced bulk-power system equipment, seeking industry input on critical issues ranging from equipment scope...

The Trump Administration has launched an unprecedented investigation into H-1B visa and PERM labor certification programs, with the Department of Labor's Office of Inspector General issuing dozens of subpoenas and suspending employers' ability to process applications. Federal agencies are deploying new enforcement tools including whistleblower programs and criminal prosecution threats...

New York City's Department of Consumer and Worker Protection secured a landmark $131.5 million settlement with DoorDash, marking the largest worker settlement in the city's history and the largest involving food delivery workers nationwide. The agreement provides over $115 million in direct compensation to more than 260,000 delivery workers who were underpaid, unpaid, or paid late, while establishing a comprehensive three-year compliance monitoring program.

The COVID-19 pandemic has significantly reshaped the facilities management (FM) outsourcing landscape. Companies have transitioned from fully office-based work to home-based work...

Two federal courts have reached opposing conclusions on whether expert witnesses must disclose their AI prompts during discovery. While one court treats prompts as discoverable methodology, another protects them as mental impressions while requiring disclosure of AI-generated outputs the expert consulted.

O "Brasília em Pauta" é um boletim semanal preparado pela equipe de Contencioso de Brasília, contendo os principais casos a serem julgados pelo Supremo Tribunal Federal (STF)...

Emerging providers of AI agents face unique contracting challenges as autonomous AI tools evolve beyond traditional SaaS models. This analysis examines critical issues in defining agent authority, structuring pricing models, calibrating warranties, and navigating regulatory uncertainty. How should providers balance customer expectations with the unpredictable nature of autonomous AI systems?

The SEC Staff has issued new guidance addressing fair value measurement and disclosure practices for private credit and other illiquid assets held by registered funds and business development companies. As private credit portfolios have grown nearly 60% since 2020, reaching $270 billion, regulators emphasize the critical importance of robust valuation methodologies, transparent disclosure of significant judgments, and careful application of accounting standards when market prices are unavailable.