The increase in tariffs imposed on the entry of Brazilian products into the United States – which may now reach up to 50% – has caused immediate cash flow pressure on companies engaged in export activities.

The hike was implemented directly through the following executive orders issued by the U.S. government this year:

• Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits, dated April 2; and
• Addressing Threats to the United States by the Government of Brazil (also referred to as the “tariff hike”), dated July 30.

Indirectly, measures such as sanctions on countries that purchase products from the Russian Federation or even those not yet formally enacted, like President Donald Trump’s announcement to impose tariffs on semiconductor products, have also contributed to this situation.

The tariff hike took effect on August 6, and this external shock has already caused and will continue to cause drastic political, financial, and fiscal consequences in Brazil. The measure has prompted state Finance Departments to begin discussions aimed at minimizing the impact on exporting companies.

Paraná has already begun to express the possibility of implementing a series of measures to protect local companies affected by the tariff hike. The proposed benefits include credit offerings, flexible investment timelines, and the use of ICMS tax credits as collateral for obtaining funds.

The Paraná government is discussing with the productive sector to mitigate the effects of the taxation and is considering new measures depending on how the situation evolves. More than R$ 400 million are expected to be made available by financial institutions to support companies in the state during this period of uncertainty.

Rio Grande do Sul has also announced measures to protect local companies from the impacts of the U.S. tariff hike.

The benefits, based on information published on the Sefaz/RS portal, include a credit program offered by the Regional Development Bank of the Extreme South (BRDE), aimed at assisting exporters from various sectors. Additionally, it was reported that Sefaz/RS will create a channel to address ICMS credits for exporting companies. The feasibility of this measure is still under discussion.

In Goiás, news published on the Sefaz/GO portal indicates discussions around creating a Credit Fund for the sectors of the local economy that export the most to the United States. This fund would invest millions of reais in ICMS credits that could be used as collateral for credit lines.

Additionally, the possibility of using the Entrepreneur Equalization Fund (Fundeq) to provide financial resources and subsidize interest payments on credit operations was mentioned. There was also discussion about using the Economic Stabilization Fund of the State of Goiás, a financial reserve intended for times of economic crisis.

Although discussions are taking place in several states, so far only the state of São Paulo has effectively adjusted its legislation, publishing regulations to mitigate the damage caused to companies affected by the tariff increase. R$ 1.5 billion in ICMS credits have already been released to authorize the transfer of accumulated credits, enabling their monetization.

Facilitating the monetization of accumulated credits can directly help exporting companies, as these companies often face significant tax inefficiencies in their operations due to high ICMS credit balances. This results from the “positive balance” in offsetting ICMS debits and credits, since their domestic purchases generally generate ICMS credit rights, while their exports do not generate ICMS debits, as there is no tax incidence on the export of Brazilian products.

Through Resolution SFP 22/25 and Ordinance SRE 43/25, the 12th round of ProAtivo was launched – a program established in 2021 to increase the liquidity of accumulated ICMS credits linked to investments in fixed assets. The goal is to authorize the transfer of accumulated credits.

The maximum authorized amount in this round will be:

• R$ 120 million for companies that exported goods directly to the United States worth more than R$ 20 million between 2021 and 2024; and
• R$ 30 million for other cases.

For exporting companies that send their goods directly to the United States, the export value will be determined based on the “product value” field recorded in electronic invoices issued by all of the company’s establishments located in the state of São Paulo.

This applies to exports to the United States made between January 1, 2021, and December 31, 2024, that were not subsequently canceled. Taxpayers must pay attention to other provisions in the legislation.

The application must be submitted by completing the request “Transfer Request for Accumulated Credit – 12th ProAtivo Round,” available in the Electronic Petitioning System (Sipet). The request must include the information specified in Ordinance SRE 43/25 and may be submitted between August 12 and September 2. Taxpayers from any economic sector may participate.

It is important to note that the transfer of accumulated credit will be made through a request in the e-CredAc System, and applications must meet the minimum value of R$ 10,000.

Our tax team is available to discuss actions and next steps to assist with joining the program.