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Legal Intelligence
Tax
WHT on dividends non-resident investors
On March 18, 2025, the government presented the Bill of Law 1087, which introduced a minimum individual income tax on high-net-worth individuals and imposes withholding income tax (WHT) on dividends paid by Brazilian legal entities to foreign...
Tax reform: updates to the layout of electronic tax documents management
The Executive Secretariat of the Management Committee of the National Standard Electronic Service Invoice (SE/CGNFS-e) released, in February, Technical Note 002 (Version 1.0). This is the second version of the new field groupings of the layout of...
Main aspects of the income tax reform proposed by the brazilian federal government
On March 18, the Brazilian Federal Government presented Bill No. 1,087/2025, which aims to tax profits and dividends and amend the income tax rules. If approved, the new rules will come into force from 2026. Main changes for Brazilian tax...
Implications of tax reform on real estate development
Tax reform has aroused great interest in the real estate development sector, as changes in the form of taxation can have significant impacts on this segment. In this article, we analyze the main changes suggested in the regulation of the reform...
MG publishes law to deal with tax settlement
Law No. 25,144/25, published on January 10 in the Official Gazette of the State of Minas Gerais, provides for the settlement of disputes related to the collection of credits from the State Treasury, of a tax and non-tax nature. The rule...
Confaz amends rule on interstate remittance
On October 7, the National Council for Finance Policy (Confaz) published ICMS Convention 109/24, which promotes changes in the rules regarding the interstate remittance of goods and merchandise between establishments of the same ownership. The...
Non-inclusion of IBS and CBS in the ICMS, ISS and IPI calculation basis
Presented on February 6, Complementary Bill 16/25 (PLP 16/25) aims to modify Complementary Law 87/96 (LC 87/96) and Complementary Law 214/25 (LC 214/25). The changes proposed in the bill provide for the non-inclusion of the Tax on Goods and...
State of SP publishes decrees to extend tax incentives
At the end of December and in the first week of January, the state of São Paulo published several decrees to extend the term of validity of certain tax incentives, as already discussed by our tax team. Considering that the non-extended tax...
Gradual reduction of the additional COFINS-import starts this year
Published on September 16, 2024, Law No. 14,973/24, among other provisions, added paragraphs 21 and 21-A to article 8 of Law No. 10,865/04, which provides for the additional Cofins-Importation. According to the paragraphs introduced, there will be...
States use trigger to increase ICMS-ST
The Federal Constitution, in its article 150, paragraph 7, provides that "the law may attribute to a taxpayer of tax obligation the condition of being responsible for the payment of tax or contribution, whose taxable event must occur later". This...
São Paulo city hall reopens deadline for joining PPI 2024
Through Decree 63,865/24, published in the Official Gazette of the City on November 4, the City of São Paulo reopened the deadline for entry into the 2024 Incentivized Installment Program (PPI) – initially instituted by Law 18,095/24 and...
Impacts of Tax Reform on distributed generation projects
The enactment of Constitutional Amendment 132/23 introduced significant changes to the Brazilian tax system, with potential impacts on various aspects of distributed generation (DG) projects. There are, at the moment, a series of tax incentives...
Stock options: current scenario and the judgment of topic 1,226 in the STJ
On September 11, the Superior Court of Justice (STJ) issued a binding precedent on Topic 1,226, , to define the incidence of Individual Income Tax (IRPF) on stock options offered by companies to employees. The understanding established by the...
New rules for import operations
On September 23, Ordinance 165/24 of the General Coordination of Customs Administration (Coana Ordinance 165/24) was published in the Brazilian Official, which provides for import operations and procedures for processing import customs clearance...
Law 14,973/24 and its developments in tax rules
Published in the Federal Official Gazette (DOU) on September 16, Law 14,973/24 brings important tax changes, among which the following stand out: transition regime of the Social Security Contribution on Gross Revenue (CPRB); updating the value of...
New rules for oil and natural gas consortia in the state of Rio de Janeiro
The Decree of the State of Rio de Janeiro 49,219/2024, published on July 26, improves the rules for the compliance with ICMS ancillary obligations in transactions carried out by Consortia in activities related to exploitation and production of oil...
CPC: proof of local holiday in appeals is made more flexible
Law 14,939/24, published on July 31, makes it more flexible to prove the occurrence of a local holiday at the timing of appeals. The legal amendment modifies paragraph 6[1] of article 1,003 of the Code of Civil Procedure of 2015 (Law 13,105/15)....
Are barriers to the import of used capital goods unrestricted?
Foreign trade issues are subjected to the rigors of tax validity and anteriority in a softened format, due to the dynamism of the activities involved and the relevance and need for customs control. However, this does not mean that the setting of...
SEFAZ/RJ introduces new obligation on ICMS Tax Incentives
On July 8, the Rio de Janeiro State Treasury Department (Sefaz/RJ) published the Sefaz Resolution 675/24, which makes it mandatory to communicate data regarding the processes of classification and adherence to ICMS tax benefits of a non-general...
New proposals for federal tax credit transactions
The Attorney General's Office for National Treasury and the Special Secretariat of the Federal Revenue of Brazil have issued two notices with proposals for the settlement of federal tax credits. The aim is to offer new methods for taxpayers and...
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