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Swap operations could unlock Brazil’s RNG
Brazil needs to increase liquidity and establish taxation to let gas swap contracts unlock constraints on biomethane trade, industry observers said. Check out the full story. (Argus -...
Ebook: New Infrastructure Debentures: Understanding Law No. 14.801/24
Our eBook provides detailed insights into the new legislation on the subject. Published on January 10, 2024, Law No. 14.801/24 introduces a new type of debenture in the infrastructure sector, with specific tax benefits and significant...
Ebook: Essential guide to the consumption tax reform: main changes and impacts for your business
Elected as a national priority, the tax reform will unify the main taxes on consumption in order to improve Brazil's business environment and boost its economic growth. To help you understand the changes and the impact of these transformations on...
State of São Paulo changes regulation of special regime
The Secretariat of Finance and Planning of the State of São Paulo (Sefaz/SP) republished, on August 9, the SRE Ordinance 52/23, which amended the regulation of requests for special regimes provided for in articles 479-A and 489 of the ICMS...
Ebook: Bill of law 4,173/2023: changes in the tax treatment of offshore assets in Brazil
Brazilian legislation on the taxation of investments abroad will undergo major changes if Bill 4.173/23 is approved in its entirety. These changes could impact the way Brazilian investors and companies operate and invest in assets outside the...
What about startups in the Tax Reform?
The agenda of the moment is undoubtedly the tax reform. Despite the wide-ranging debate on the subject in recent years, the most recent discussions in the National Congress make it clear that the proposal, in addition to lacking definitions on how...
FIP: change in the tax regime for non-resident investors
On October 3, 2023, the Brazilian National Congress approved the bill of law n. 4,188/2021 (known as the “legal framework of guarantees”) that among other changes, modified the legal requirements for the application of 0% Withholding Income Tax...
Labor Reform and taxation
The Labor Reform (Law 13.467/17) changed, among other points, rules on the breaks for rest and feeding during the working day. Before the Labor Reform, in force since November 11, 2017, there were discussions about whether the payment resulting...
Clash over taxation of investment subsidies
The discussion on the (non) taxation of revenues arising from investment subsidies granted by Brazilian states to taxpayers has recently taken on new contours with the judgment of Theme 1,182 by the Superior Court of Justice (STJ). The...
New norm for exemption from Tax Infraction Notices in SP
The State Treasury Office of the State of São Paulo published, on July 31, SRE Ordinance 51/23, which repeals CAT Ordinance 115/14, which may represent a setback in relation to the measures already in place for the exemption from the issuing of...
ICMS on the transfer of products between establishments of the same entity
In the judgment of the Direct Action for Constitutionality[1] 49 (ADC 49), the Supreme Constitutional Court (STF) ruled that the levy of ICMS on transfers between establishments of the same entity is unconstitutional. According to the judgment,...
Ebook: MP 1152 – New transfer pricing rules
Brazil introduced Provisional Measure No. 1152 on December 29, 2022, updating its transfer pricing rules to align more closely with international standards, especially as the country evaluates its integration with the OECD. The new rules, which...
Statute of limitations of customs charges
Section 1, paragraph 1, of Law 9,873/99, establishes a limitation "in the administrative proceeding, paralyzed for more than three years, pending judgment or order”, determining its ex officio cancelation. In the scope of tax law, reaching the...
Calculation basis of PIS and Cofins for the insurance sector
The Supreme Court concluded, on June 12, the trial of motion for clarification filed in the extraordinary appeal 400,479 (RE 400,479), whose objective was to define the scope of the concept of billing for companies in the insurance sector in the...
Use of judicial performance bond and bank guarantee
In recent years, although the Superior Court of Justice (STJ) has established theories on the use of performance bonds or bank guarantee as security in tax litigation, taxpayers still face legal uncertainty regarding the effects of presenting...
New developments on the casting vote with the Carf
One of the first measures adopted by the new government, in January of this year, was the promulgation of Executive Order 1,160/23, which reinstated the casting vote as a tiebreaker criterion in judgments by the Administrative Council for Tax...
House of Representatives approves resumption of the casting vote at Carf
The House of Representatives approved, in plenary session on July 7, the Bill of Law 2.384/23, which resumes the casting vote at the Administrative Tax Court (Carf). The approved text is the replacement suggested by the rapporteur, Mr Beto Pereira...
Ebook: Tax Reform on consumption
The Tax Reform was elected as a priority to unlock Brazil's economic growth and improve the business environment. The proposal already approved in the House of Representatives seeks to unify the main consumption taxes and create a simpler and...
MP 1,152/22 is approved by the House of Representatives
The House of Representatives approved, on March 30, Executive Order 1,152/22, which amends the legislation of the Corporate Income Tax (IRPJ) and the Social Contribution on Net Profits (CSLL) to provide for transfer pricing rules. The approval...
Impacts of SC Cosit 85/23 on corporate taxation
The Federal Revenue Service of Brazil (RFB), through its General Coordination of Taxation (Cosit), published, on April 12, the Private Letter Ruling Cosit 85/23 (SC Cosit 85/23), to determine the limits of the restriction on the use of tax Net...
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