Brazil: Corporate Tax

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.

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.

This weekly bulletin from Mayer Brown's Brasília litigation team highlights key cases scheduled for judgment by Brazil's Supreme Federal Court, Superior Court of Justice, and Federal Court of Accounts, along with important legislative matters before the Chamber of Deputies and Federal Senate. The briefing covers critical legal developments across banking, civil procedure, energy infrastructure, insurance, telecommunications, and tax law that will shape Brazil's regulatory landscape.

The Brazilian Internal Revenue Service has introduced two new tax settlement programs through Public Notices No. 9/2026 and No. 10/2026, offering taxpayers opportunities to resolve administrative tax disputes with significant discounts and flexible payment terms. These programs target different taxpayer categories based on debt size and business classification, with application deadlines set for October 30, 2026.

A Receita Federal estabeleceu novo entendimento sobre a tributação de parcelas complementares em operações de alienação de participação societária sujeitas a condições suspensivas. A Solução de Consulta COSIT nº 96/2026 diferencia o tratamento tributário entre pagamentos contingentes e preços determinados, com impactos significativos na aplicação das alíquotas progressivas de IRPF sobre ganho de capital.

The Brazilian Federal Supreme Court has reached a majority decision on the constitutionality of penalties for companies distributing profits while carrying outstanding tax debts. The ruling establishes specific conditions under which such distributions are prohibited, creating new compliance requirements for corporate profit distributions. Companies must now carefully evaluate their tax positions before approving dividend payments and bonuses to shareholders and managers.

Matheus Barreto and Guilherme Becker analyze the limits set by Brazil's Supreme Federal Court for isolated tax penalties and their impacts on taxpayers, examining how the ruling balances educational sanctions with the need to preserve trust between tax authorities and contributors.

The new proposal foresees conditional exemptions and imposes a Minimum Income Tax for high incomes, but raises doubts about its complexity...

The Group of 20 (G20) countries is exploring plans for a global minimum wealth tax that would apply to the world's 3,000 billionaires.