Brazil’s Split Payment for IBS and CBS: How Will It Work in Practice?
On June 3, 2026, Joint Act No. 2 of May 27, 2026 — issued by the Brazilian Federal Revenue Service (Receita Federal do Brasil — RFB) and the IBS Management Committee (Comitê Gestor do IBS — CGIBS) — was published in the Federal Official Gazette (Diário Oficial da União). The act authorized the release, on […]
Tax settlement: the conditions of PGFN Public Notice No. 6/2026
The Office of the Attorney General of the National Treasury (Procuradoria-Geral da Fazenda Nacional — PGFN) published, in the Official Gazette of June 1, 2026, Public Notice No. 6/2026 (Edital nº 6/2026), which opens a new opportunity to regularize debts registered as overdue federal debt (dívida ativa da União) through a tax settlement by adhesion […]
PIS and COFINS credits on IPTU and condominium fees: part of the cost of the lease?
The possibility of taking credits of PIS and COFINS — the federal Social Integration Program Contribution (PIS) and Social Security Financing Contribution (COFINS) — on the Urban Property Tax (IPTU) and the condominium fees paid by the tenant, in respect of properties used in the business, is a controversy of significant impact for companies with […]
IBS and CBS regulations: an overview of Brazil’s consumption tax reform
On April 30, 2026, the regulations for the two central taxes of the consumption tax reform were published: Decree No. 12,955/2026, which regulates the Federal Contribution on Goods and Services (Contribuição sobre Bens e Serviços — CBS), within the federal government’s jurisdiction; and Resolution No. 6/2026 of the IBS Management Committee (Comitê Gestor do IBS […]
Amortization of goodwill (ágio): the “real acquirer” theory before the CARF
The deductibility of the amortization of goodwill (ágio) for purposes of Corporate Income Tax (IRPJ) and Social Contribution on Net Profits (CSLL) is one of the most frequent and highest-value tax disputes arising from acquisitions of equity interests. A series of recent decisions indicates that the Federal Administrative Tax Court (Conselho Administrativo de Recursos Fiscais […]