State and Local Tax Updates

Federal

Federal Revenue Service amends Confia Program rules and introduces new benefits for certified taxpayers

On March 23, 2026, the Federal Revenue Service published a Normative Instruction amending several aspects of the Cooperative Tax Compliance Program (Confia), within the scope of the Special Secretariat of the Federal Revenue Service.

The rule updates relevant topics of the program, such as relevant tax acts or transactions, tax and customs matters, and administrative penalties, and also formally establishes the Confia Brand and the Confia Seal, intended to identify certified taxpayers.

Among the main changes, particular emphasis should be given to the expansion and detailing of the benefits granted to program participants, including authorization to use the Confia Seal, participation in dialogue forums for improvement of the model, prioritization of requests before the Federal Revenue Service, and preference as a tie-break criterion in public tenders, subject to the legislation applicable to small-sized companies.

The Normative Instruction also regulates the tax compliance bonus, corresponding to a 1% discount on the lump-sum payment of CSLL, subject to progressive annual caps and conditioned on the length of time the seal is maintained.

In addition, the rule reinforces duties related to tax governance, requiring employee training, an adequate technological structure, remediation of identified failures, and broad and aggregate disclosure of the tax policy and internal procedures to interested parties and to the public.

Lastly, the text provides that, while admitted to Confia, the taxpayer will not be subject to classification as a habitual debtor and details the effects of debt regularization, including cases of non-application or reduction of administrative penalties.

The Normative Instruction will enter into force on April 9, 2026.

Federal Revenue Service regulates the Sintonia Program

On March 27, 2026, the Federal Revenue Service published a Normative Instruction regulating the Tax Compliance Incentive Program (Sintonia). The program is intended to encourage compliance with principal and ancillary tax and customs obligations, as well as to strengthen the security of the national and international supply chain.

Sintonia covers active legal entities taxed under the actual profit, presumed profit, or arbitrated profit regimes, entities exempt from or immune to IRPJ and CSLL, and taxpayers subject to Simples Nacional. Excluded, among others, are individuals, individual microentrepreneurs, public bodies, and companies with less than six months of registration with the National Register of Legal Entities (CNPJ).

Taxpayer classification will be carried out monthly based on criteria related to registration data, tax returns and bookkeeping, consistency of information, and payment of taxes.

The final score will be calculated based on weighted averages of the monthly scores, with greater weight given to more recent periods, and will result in taxpayers being classified in the following categories:

Classification	Final Score
“A+”	Greater than or equal to 0.995 (99.5%)
“A”	From 0.970 (97%) to 0.994 (99.4%)
“B”	From 0.900 (90%) to 0.969 (96.9%)
“C”	From 0.700 (70%) to 0.899 (89.9%)
“D”	Less than 0.700 (70%)

Disclosure of the classification will occur quarterly and will be restricted to the taxpayer, except in the case of category A+, whose classification may be made public.

The Normative Instruction also creates the Sintonia Seal, to be granted to taxpayers classified as A+, valid for one year and automatically renewable. Holders of the seal will have priority in several Federal Revenue Service services and access to legal benefits, such as the CSLL tax compliance bonus, subject to the applicable caps and requirements.

The Normative Instruction will enter into force on April 9, 2026.

Federal Revenue Service details bookkeeping criteria for PIS/Cofins following Complementary Law that reduced federal tax benefits

At the end of March, the Federal Revenue Service updated, for the second time, its Questions and Answers material regarding the Complementary Law dealing with the reduction and criteria for the granting of incentives and benefits of a tax, financial, or credit nature granted exclusively within the scope of the Federal Government.

The first version of the material had been published in January 2026, with clarifications on conceptual questions regarding the impacts of the Complementary Law. In the new version, answer 34.1 was included, clarifying the procedures applicable to transactions previously subject to the zero rate of PIS and Cofins and that became subject to the levy corresponding to 10% of the standard rate of the contributions on the calculation base.

According to the clarification, these transactions must continue to be documented under Tax Situation Code (CST) 06, relating to transactions taxed at a zero rate for purposes of PIS and Cofins. In addition, the invoice must include, in the field for additional information of interest to the tax authorities, reference to the Complementary Law, in order to ensure the proper identification and traceability of the transaction.

With respect to PIS and Cofins credits, the Federal Revenue Service reaffirmed that the refund and offsetting system remains unchanged, including for revenues subject to the zero rate as a result of the linear reduction of benefits. It was also clarified that amounts arising from the rate increase resulting from such reduction do not generate credit rights for the purchaser.

Complementing these clarifications, a Technical Note was published with guidance on bookkeeping in the EFD-Contributions. The document establishes that the tax situation codes originally provided for must not be changed and that the adjusted amounts must be reflected through the existing credit and debit adjustment records in the layout of the ancillary obligation, in Block M, intended for the calculation of the contributions.

Federal Revenue denies PIS and Cofins credits on depreciation and maintenance of assets leased to clients

On March 2, 2026, the Federal Revenue Service published a Private Ruling issued by the Tax Division of the Regional Superintendencies (Disit) on the possibility of taking PIS and Cofins credits related to the depreciation of machinery, equipment, and other fixed assets provided free of charge to customers, as well as expenses incurred with the maintenance and sterilization of such surgical instruments, in light of the concept of inputs.

In the case under review, the requesting taxpayer operated in the resale of surgical and orthopedic products, supplying goods to hospitals, clinics, and other healthcare establishments for use in surgical procedures.

The Federal Revenue Service concluded that, in the context of commercial activity, there is no legal basis for the appropriation of such credits, since this possibility is limited to activities involving the manufacture of goods and the provision of services. In addition, it emphasized that the gratuitous lending of assets to third parties does not fall within the credit-generating events permitted under PIS and Cofins legislation.

Federal Revenue Service clarifies that ICMS-Difal may be excluded from the PIS and Cofins calculation base

On March 2, 2026, the Federal Revenue Service published a Disit Private Ruling clarifying that the ICMS rate differential (ICMS-Difal) levied on interstate transactions destined to a non-taxpayer final consumer located in another State may be excluded from the PIS and Cofins calculation base under the non-cumulative regime.

According to the interpretation set forth, the exclusion is allowed provided that the sales revenue is not subject to the suspension, exemption, zero-rate, or non-levy regimes applicable to the contributions, and that the ICMS amount is highlighted in the tax document.

Federal Revenue Service clarifies criteria for applying the concentrated PIS and Cofins regime to auto parts

On March 3, 2026, the Federal Revenue Service published a Disit Private Ruling providing guidance on the application of the concentrated PIS and Cofins regime in the auto parts sector.

According to the interpretation adopted, the regime applies only to products that may be classified as auto parts, that is, items capable of being used in the manufacture of the vehicles and machinery provided by law or in the production of other auto parts listed in the applicable rules.

The guidance further states that whenever it is not possible to rule out such potential use of the product, the applicability of the concentrated regime should be analyzed in light of the specific rules set forth in the legislation governing the regime.

Complementary Law reduces PIS and Cofins for the chemical and petrochemical industry in 2026

On March 20, 2026, a Complementary Law was published reducing the PIS and Cofins rates levied on the chemical and petrochemical industry.

Within the scope of the Special Regime for the Chemical Industry (REIQ), the rule provides for differentiated rates for taxable events occurring between January 2025 and February 2026 and, subsequently, for the period from March through December 2026, resulting in a significant reduction in the tax burden. The changes apply to sales made by chemical and petrochemical industries and cover various inputs and products used in the sector’s production chain.

The Complementary Law also reduced the rates of the contributions applicable to producers and importers of petrochemical naphtha, establishing differentiated percentages for the same periods.

In addition, caps were established for the tax expenditure resulting from the benefits granted under the special regime in fiscal year 2026: up to BRL 2 billion for certain benefits and up to BRL 1.1 billion for other specific incentives provided by law. Should these caps be reached, the benefits will be terminated as from the month following confirmation that the established amounts have been exhausted.

The Complementary Law entered into force on the date of its publication.

Federal Revenue Service amends rules on refunds, offsets, and export-related tax credits

The Brazilian Federal Revenue Service published a Normative Instruction introducing relevant changes to the rules governing tax refunds, offsets, and the calculation of tax credits, including under the Acredita Exportação Program, which allows micro and small exporting companies to recover part of the taxes levied throughout the production process of exported goods.

Among the main changes, particular emphasis should be given to the provision establishing that Reintegra regime will now apply exclusively to export transactions whose customs clearance was processed through the Single Export Declaration (Declaração Única de Exportação – DU-E).

The rule also defined the criteria for classification as a microenterprise or small-sized company for purposes of calculating credits under the Acredita Exportação Program, taking into account: (i) the company’s election for the Simples Nacional regime in the calculation quarter; or (ii) the gross revenue of the previous calendar year. For companies not subject to Simples Nacional, the refund request and the offset declaration will now depend on the prior filing of the Tax and Accounting Bookkeeping (Escrituração Contábil Fiscal – ECF).

In addition, the Normative Instruction amended the cases in which offsetting will not be allowed, including those involving: (i) credits not administered by the Federal Revenue Service; (ii) credits covered by a binding precedent issued by the Brazilian Supreme Court; and (iii) PIS and Cofins non-cumulative credits unrelated to the taxpayer’s business activities.

Another relevant innovation was the establishment of monthly limits for the offsetting of credits arising from final and unappealable court decisions, according to the total amount of the credit. The minimum period for use may range from 12 to 60 months, depending on the value bracket, and does not apply to credits below BRL 10 million.

The changes entered into force on March 19, 2026, the date of publication of the Normative Instruction.

Subsidy for diesel fuel and tax measures to mitigate the increase in fuel prices

In view of the current international geopolitical scenario and with the purpose of mitigating the effects of rising oil prices, a Provisional Measure was published on March 12, 2026 authorizing the granting of an economic subsidy for the commercialization of road diesel fuel in the national territory.

The benefit corresponds to BRL 0.32 per liter and may be granted from March 12, 2026 through December 31, 2026, subject to an overall cap of BRL 10 billion. The subsidy will be granted to producers and importers of diesel fuel duly authorized by the Brazilian National Agency of Petroleum, Natural Gas and Biofuels (ANP).

Receipt of the subsidy will depend on prior qualification through the execution of an accession instrument, as well as authorization for the sharing of tax information with the Brazilian Federal Revenue Service.

The Provisional Measure also introduced an Export Tax, at a rate of 12% on exports of crude petroleum oils and 50% on exports of diesel fuel, for as long as the subsidy remains in force.

On the same date, a Decree was published reducing the PIS and Cofins rates levied on the importation and commercialization of diesel fuel. Through May 31, 2026, a reduction coefficient of 0.99987 was established for the contributions applicable to diesel fuel and its fractions.

Congress enacts legislative decree approving the Partnership Agreement between Mercosur and the European Union

On March 17, 2026, the National Congress enacted the Legislative Decree approving the Partnership Agreement between Mercosur and the European Union. The treaty represents one of the most relevant trade agreements entered into by the bloc and establishes one of the world’s largest bilateral free trade areas.

With respect to trade in goods, the agreement provides for broad tariff elimination commitments, especially in the agricultural sector. In this segment, the European Union undertook to liberalize 77% of tariff lines, corresponding to more than 80% of trade. Products of interest to Brazil, such as meat, fruits, grains, coffee, sugar, and ethanol, will benefit from preferential access through quotas and progressive tariff reductions.

In the industrial sector, the European Union will eliminate 100% of tariffs within up to ten years, with approximately 80% already liberalized upon entry into force of the agreement. Mercosur, in turn, will adopt longer timeframes, of up to 30 years, for sensitive products, in addition to providing for special customs regimes, such as drawback, and mechanisms that favor integration into global value chains.

Following the promulgation of the Legislative Decree, Brazil will proceed with the ratification formalities before Paraguay and the European Union, which act as depositaries of the instrument. Once this stage is completed, the agreement must still be aproved domestically by presidential decree.

Federal Revenue Service launches pilot customs cooperation project with the United States

On March 17, 2026, the Federal Revenue Service published an Ordinance establishing a pilot project for the exchange of information for cargo risk management under customs cooperation with U.S. Customs and Border Protection, within the framework of the Container Security Initiative (CSI) Program.

The initiative is experimental and collaborative in nature and is aligned with the Mutual Assistance Agreement between the customs administrations of Brazil and the United States, as well as with domestic rules governing information sharing.

Its main objectives include strengthening international customs cooperation for the prevention, investigation, and repression of violations, improving information exchange and risk management in international trade, and enhancing the security and integrity of the logistics chain. The project also seeks to assess operational cooperation mechanisms between the administrations involved and to expand initiatives already developed under the CSI.

The Ordinance entered into force on the date of its publication in the Official Gazette of the Union.

Federal Revenue Service reinforces literal interpretation for qualification under Ex-tariff regime

On March 20, 2026, a Private Ruling issued by the General Coordination of Taxation of the Federal Revenue Service (Cosit) was published regarding the qualification of imported goods under Ex-tariff regime for purposes of reducing the Import Tax rate.

The interpretation reaffirms that tax benefits must be construed restrictively and literally, pursuant to the National Tax Code and the Customs Regulation, requiring full compliance of the goods with the specifications set forth in the granting act.

The ruling request was submitted by a taxpayer operating in the wholesale trade of medical-hospital products, which questioned whether the expression “may have,” contained in the description of the applicable Ex-tariff should be understood as a mere possibility or as a mandatory requirement concerning certain product characteristics.

In response, the Federal Revenue Service clarified that qualification under Ex-tariff requires complete correspondence between the imported goods and the regulatory description, including dimensions and other technical specifications. Accordingly, even expressions that, at first glance, indicate possibility do not eliminate the need for strict adherence to the characteristics set forth, given the exceptional nature of the benefit.

Federal Government establishes the Brazilian system of official export credit support

On March 25, 2026, a Law was published establishing the Brazilian system of official export credit support, recognizing such activities as essential to industrial, services, and foreign trade policy.

The rule provides for direct and indirect support mechanisms and authorizes the participation of private lenders and insurers as operators, with operating rules to be defined by regulation and subject to periodic review, including the possibility of public consultation with the relevant stakeholders.

The Law also expands the possibilities for insurance and financing of productive investment projects in the national territory aimed at the export of highly technological goods and services or those related to the green economy.

Another noteworthy aspect is the provision for the creation of a single online portal for requests for official export credit support, which will allow the parallel processing of requests among different operators and the reuse of documents.

The Law entered into force on the date of its publication

Federal Revenue Service extends migration schedule to Duimp               

In March, the Federal Revenue Service published a notice extending the deadline for processing, through the Import Declaration (DI), transactions whose definitive migration to the Single Import Declaration (Duimp) had originally been scheduled for March 23, 2026 and March 30, 2026.

Under the revised schedule, the new dates for discontinuation of the DI for such transactions became April 22, 2026 and April 27, 2026, respectively.

The change results from a decision of the Siscomex Management Committee and seeks to ensure greater safety, operational stability, and predictability for imports during the transition period to Duimp.

The Federal Revenue Service emphasized that the Duimp system remains available for the filing of customs declarations relating to all imports, except for those expressly indicated as unavailable in the discontinuation schedule published on the Siscomex Portal.

Federal Revenue Service consolidates rules of the Brazilian Authorized Economic Operator (OEA) Program

On March 27, 2026, the Federal Revenue Service published a Normative Instruction governing the Brazilian Authorized Economic Operator Program (OEA). The rule consolidates the provisions relating to certification, criteria, benefits, and procedures applicable to foreign trade participants. The program remains voluntary and will now be fully operated through the OEA System.

The Normative Instruction defines the participants eligible for certification, such as importers, exporters, carriers, freight forwarders, warehouse operators, and port and airport operators, in addition to regulating the certification modalities: OEA-Security (OEA-S) and OEA-Compliance (OEA-C), the latter subdivided into Essential, Qualified, and Reference levels. It also establishes general, security, and customs compliance criteria, as well as mandatory and recommended requirements for admission to and continued participation in the program.

Among the benefits provided are reduced selection for customs inspection channels, priority treatment of declarations, exemption from guarantees under certain customs regimes, and the possibility of early filing of declarations. For OEA-C Reference, noteworthy benefits also include deferred payment of import taxes and exemption from submission to channels other than the green channel, except in risk situations.

The rule also governs the certification, validation, monitoring, and periodic revalidation process every four years, as well as the grounds for exclusion from the program, including ex officio exclusion, and creates the OEA Consultative Forum as a permanent channel for dialogue between the Federal Revenue Service and certified operators.

The Normative Instruction entered into force on March 27, 2026, the date of its publication, with specific transitional provisions for certification applications filed in the OEA System by July 31, 2024.

Acre

Acre amends rules on accumulated ICMS credits and tax inspection

By means of a decree published on March 18, 2026, the State of Acre introduced amendments to the ICMS Regulation regarding the use of accumulated credits, the inspection of goods in transit, and the rules on tax prepayment, rate differential, and deferral of the tax.

Among the changes, particular emphasis should be given to the possibility for the taxpayer to choose whether or not to consider internal transfers between establishments under the same ownership for purposes of calculating the requirement applicable to the use of accumulated credits to settle tax debts unrelated to the regular ICMS offsetting system.

The decree also regulated inspections at tax checkpoints, authorized the non-issuance of ICMS notices in certain low-value cases, and adjusted rules applicable to interstate transactions carried out by taxpayers benefiting from state tax incentives. In addition, it removed the requirement to pay the ICMS rate differential on interstate transfers of goods for use, consumption, and fixed assets between establishments under the same ownership, and started to allow the deferral of ICMS upon customs clearance of imported goods destined for the industrial process of companies benefiting from a special regime.

Alagoas

Alagoas excludes the perfumery, personal hygiene, and cosmetics sector from the Optional ICMS-ST Regime (ROT-ST)

In a normative instruction published on March 20, 2026, the State of Alagoas excluded the perfumery, personal hygiene, and cosmetics segment from the Optional ICMS Tax Substitution Taxation Regime (ROT-ST).

According to the rule, the exclusion was motivated, among other factors, by differences in interpretation between the tax authorities and part of the taxpayers in the sector regarding the inclusion of franchise-related amounts in the ICMS-ST calculation base, as well as by the difficulty of controlling, in certain transactions, cases in which such amounts are passed on to the retail reseller by an intermediary distributor. According to the tax administration, this scenario has generated a mismatch between the presumed calculation base and the price actually charged to the final consumer, with a negative impact on tax collection.

As a result of the exclusion of these products from the regime, the normative instruction establishes that, for taxpayers in the segment currently opted into the ROT-ST: (i) if the election occurred by December 31, 2025, the exclusion will take place automatically as from January 1, 2027; and (ii) if the election occurred as from January 1, 2026, the exclusion will take place automatically on the first day of the month following completion of 12 months from the election.

The rule entered into force on the date of its publication.

Amapá

Amapá details criteria for data cross-checking and monitoring by tax authorities

In an ordinance published on March 4, 2026, the State of Amapá amended provisions of the legislation applicable to voluntary tax regularization, especially to provide that the tax authorities may notify taxpayers whenever indications of irregularities are identified, in order to allow the regularization of their tax obligations.

The Ordinance also clarifies that such irregularities may be identified on the basis of: (i) electronic cross-checking of information; (ii) computerized data analysis; (iii) analysis of filed tax returns; and (iv) continuous monitoring of the taxpayer’s tax compliance.

The rule entered into force on the date of its publication.

Espírito Santo

Espírito Santo publishes regulation of the DC-e

On March 26, 2026, the State of Espírito Santo published a decree amending the ICMS Regulation to require, as from April 6, 2026, the issuance of the Electronic Content Declaration (Declaração de Conteúdo eletrônica – DC-e) and the Auxiliary Electronic Content Declaration (Declaração Auxiliar de Conteúdo eletrônica – DACE) in transactions involving the transportation of goods whenever the issuance of a tax document is not required.

Among the matters addressed by the regulation are issuer accreditation, DC-e cancellation, consultation of the document, delivery to the recipient and the carrier, as well as the provision that issuance may be prohibited for users who, on a habitual basis or in a volume indicating commercial intent, carry out transactions involving the circulation of goods subject to ICMS.

The decree entered into force on the date of its publication.

Goiás

Goiás expands the Negocie Já II self-regularization program to cover taxable events through September 2025

By means of a normative instruction published on March 11, 2026, the State of Goiás expanded the scope of the Negocie Já II Program to include debts arising from taxable events occurring through September 30, 2025.

The Negocie Já II Program brings together facilitating measures for the settlement of state tax debts, including ICMS. Originally, only debts related to taxable events occurring through March 31, 2025 were covered.

The amendment entered into force on the date of its publication, with retroactive effects as from February 1, 2026.

Goiás grants remission of ICMS credits on internal transfers of cattle between agricultural producers

In the State of Goiás, a law published on March 18, 2026 granted remission of ICMS tax credits arising from internal transfers of cattle carried out between agricultural producers under an ICMS exemption, provided that the transactions are supported by an Animal Transit Form or Animal Transfer Instrument.

The measure covers assessed or unassessed tax credits, whether or not enrolled in active debt collection, including those already under judicial collection, provided that they relate to taxable events occurring by December 31, 2023.

Enjoyment of the remission is conditioned upon withdrawal from lawsuits, objections to tax foreclosure, administrative challenges, defenses, and appeals related to the respective credits, with waiver of the underlying rights under discussion, full payment of court costs and procedural expenses, and waiver by the taxpayer’s counsel of the right to collect court-awarded attorneys’ fees.

The rule also provides that the extinguishment of the tax credit does not authorize the refund or offset of amounts already paid or offset, nor the release of amounts previously deposited.

The law entered into force on the date of its publication.

Minas Gerais

Minas Gerais regulates provisional ICMS exemption on imports of products without a domestic equivalent technical report

In a resolution published on March 11, 2026, the State of Minas Gerais regulated the procedure for recognition of the ICMS exemption on the entry of imported goods or merchandise without a domestic equivalent, in cases in which the report attesting the absence of a similar domestic product cannot be submitted at the time of release by the customs authority. In such cases, provisional recognition of the benefit by the state tax authorities is authorized.

The Resolution establishes that the exemption request must be filed through the Minas Gerais State Revenue Service portal, together with the relevant supporting documentation.

The rule also provides that, if the report is not submitted within the required period, if legal requirements are not met, or if the exemption request is denied, ICMS will be due as from the date of customs clearance, plus the applicable legal charges, without prejudice to tax assessment.

The Resolution entered into force on the date of its publication.

Minas Gerais receives authorization from Confaz to grant ICMS tax benefits to taxpayers affected by the heavy rainfalls

The National Council for Fiscal Policy (Confaz), through an agreement approved on March 5, 2026, authorized the State of Minas Gerais to grant ICMS tax benefits to taxpayers affected by the heavy rains that resulted in the declaration of a state of public calamity.

Among the authorized benefits, particular emphasis should be given to the exemption applicable to outbound transactions arising from the sale of goods destined for fixed assets, as well as their parts and components, to establishments of taxpayers located in municipalities declared to be in a state of public calamity. The exemption covers internal and interstate transactions, including with respect to ICMS-Difal, as well as outbound donations.

It was also authorized: (i) the extension of the deadline for payment of ICMS; (ii) the waiver of interest and penalties; and (iii) the waiver of the requirement to reverse credits related to the entry of goods held in inventory and lost as a result of the climate events.

To enjoy the benefit, the taxpayer must declare, in accordance with domestic legislation, that it was affected by the climate events listed in state legislation and in the ICMS Agreement.

The Agreement produces effects through December 31, 2026.

Confaz waives issuance of tax documents for donations intended for victims of the floods in Minas Gerais

A waiver of the requirement to issue a tax document was established for transactions and transportation services related to the shipment of donated goods intended to assist victims of the floods that occurred in February 2026 in the State of Minas Gerais.

The measure covers shipments of items collected from third parties, whether carried out by taxpayers or non-taxpayers, provided that the goods are accompanied by a content declaration and are addressed to the State Government, Civil Defense, municipalities affected, or non-profit charitable entities located in Minas Gerais.

The normative act also clarifies that, when the donation involves goods belonging to the sender itself, the issuance of an Electronic Invoice (NF-e) remains mandatory, using the specific Fiscal Operation and Service Codes (CFOPs) applicable to bonus shipments, donations, or gifts.

The documentary simplification seeks to enable a faster shipment of goods intended for emergency assistance, while preserving tax controls in situations where the taxpayer itself donates goods from its inventory.

The waiver is temporary in nature and produces effects through June 30, 2026, being particularly relevant for companies and organizations involved in fundraising campaigns and donation logistics.

Pará

Pará allows extension of the mandatory issuance of NFCom by means of a special regime

On March 13, 2026, the State of Pará published a decree amending the ICMS Regulation to allow the extension of the mandatory issuance of the Electronic Communication Services Invoice (NFCom, model 62). If the requirements established by the legislation are met, the extension may last until August 1, 2026, provided that the taxpayer requests a special regime and complies with the specific conditions established.

Among such conditions, particular emphasis should be given to the requirement that, in November 2025, the taxpayer must have reached at least 60% issuance of NFCom in relation to the total number of tax documents used, in addition to the obligation to subsequently issue the corresponding NFComs for the transactions carried out during the period, including information related to IBS and CBS, where applicable.

The ICMS Regulation also ceased to require the prior submission of special systems for purposes of joining the regime, without prejudice to the possibility of revocation in the event of non-compliance with the established conditions.

If the request is submitted within 30 days from publication of the decree, the regime may produce retroactive effects as from November 1, 2025, which may affect the tax regularization of prior periods.

Paraná

Paraná updates ICMS rules applicable to the Temporary Admission Regime

On February 27, 2026, the State of Paraná published a decree amending the ICMS Regulation with respect to transactions carried out under the Temporary Admission Regime.

The deadlines applicable for purposes of ICMS exemption were updated, in line with federal legislation, and provisions were included to detail the procedures for collection of the tax in the event of non-compliance with the conditions of the regime. The legislation also started to govern the regularization of ICMS due in cases of non-compliance with or termination of the regime, as well as in cases involving the nationalization of temporarily imported goods.

The decree also amended the provisions relating to the ICMS taxable base reduction applicable to temporary imports for economic use, establishing formalities to be observed in requesting the treatment and criteria for calculating the portion of the tax due.

The changes apply immediately.

Paraná excludes electronic products, electrical appliances, and household appliances from the ICMS-ST regime

On February 27, 2026, the State of Paraná published a decree excluding several electronic products, electrical and electronic products, and household appliances from the ICMS tax substitution regime.

The affected products include cell phones, stoves, refrigerators, printers, multifunction devices, and their respective parts and accessories, identified in the legislation by means of the Tax Substitution Specification Code (CEST) and Mercosur Common Nomenclature (NCM) classification.

As a result of the change, ICMS on transactions involving such products in the State of Paraná returns to the regular tax calculation system.

The amendments produce retroactive effects as from March 1, 2026.

Paraná expands criteria for transfer of ICMS credits linked to exports to the United States

On March 5, 2026, the State of Paraná published a resolution establishing criteria, limits, and conditions for the transfer of own credits qualified in the “Investment Account” of the Accumulated Credit Transfer and Utilization Control System (Siscred). The act was adopted in the context of tax measures implemented in response to tariffs imposed by the United States on Brazilian products destined for export.

Under the amendment, the criteria for calculating the export value considered in defining the balance of transferable credits were broadened. Indirect exports carried out by subsidiary companies belonging to the same economic group as the company established in the State of Paraná may now also be included, provided that the latter holds an equity interest corresponding to the entirety of the share capital of the company responsible for the transactions.

The rule produces effects as from the date of its publication and may affect exporting companies that use Siscred for the management and transfer of ICMS credits.

Rio de Janeiro

Rio de Janeiro introduces new provisions in the regulation of the FOT

On March 24, 2026, the State of Rio de Janeiro published a decree amending and introducing rules relating to the contribution to the Temporary Budgetary Fund (FOT), required from taxpayers benefiting from ICMS tax incentives.

Among the main provisions, particular emphasis should be given to the definition of the method for calculating the amount due, requiring taxpayers to identify, within the total amount of the tax relief, the portion corresponding to each tax benefit used in the period. The specific percentages established by law must be applied to these individualized amounts, followed by consolidation for purposes of calculating the total monthly amount due to the FOT.

The amendments entered into force on the date of publication of the decree, producing effects as from April 1, 2026.

Rio Grande do Norte

Rio Grande do Norte changes rules for simplified analysis of ICMS-ST refund claims

On March 7, 2026, the State of Rio Grande do Norte published an ordinance amending the procedures for approval of refund claims involving ICMS amounts collected under the tax substitution regime (ICMS-ST).

Under the change, in order for the request to be analyzed under the simplified procedure, the amount claimed as a refund must be lower than BRL 50,000.00 per tax calculation period.

The rule also establishes that the tax auditor in charge must verify, within a maximum period of 30 days from receipt of the administrative proceeding and the required documentation, whether the taxpayer meets the requirements for qualification under such simplified procedure.

Rio Grande do Sul

Rio Grande do Sul restricts the transfer of ICMS credits between establishments of the same company

On March 3, 2026, the State of Rio Grande do Sul published a decree, with retroactive effects as from November 1, 2024, amending the ICMS Regulation based on ICMS Agreements No. 109/2024 and No. 7/2026.

The normative act establishes that the possibility of transferring ICMS credits in interstate transactions involving goods destined for another establishment of the same company does not apply to the non-levy cases provided for transactions involving electricity, petroleum, and their derivatives — except when subject to the single-phase regime — destined for industrialization or commercialization, nor to transactions involving goods destined abroad.

Rio Grande do Sul makes issuance of the DC-e mandatory

On March 3, 2026, the State of Rio Grande do Sul published a decree amending the ICMS Regulation to incorporate Sinief Adjustment No. 5/2021 and establish the mandatory issuance of the Electronic Content Declaration (DC-e) as from April 6, 2026.

The DC-e must accompany the transportation of goods and merchandise in situations in which the issuance of another tax document is not required, such as transactions carried out by companies that are not ICMS taxpayers, including returns.

Accordingly, issuance of the DC-e becomes mandatory in the State as from April 6, 2026.

Rio Grande do Sul expands the situations allowing transfer of accumulated ICMS credits

On March 20, 2026, the State of Rio Grande do Sul amended the ICMS Regulation to expand the situations allowing the transfer of accumulated ICMS credits.

The new situations cover: (i) industrial establishments manufacturing cellulose, with respect to credit balances arising from specific deemed tax credits provided for in state legislation; and (ii) industrial establishments whose credit balance arises from subsequent transactions subject to ICMS deferral, with the transfer limited to credits linked to the acquisition of goods classified under NCM code 7201.10.00 and used in the production process.

The new rules entered into force on March 20, 2026.

Rio Grande do Sul introduces new requirement for enjoyment of tax benefit by manufacturers of electronics and IT products

On March 25, 2026, the State of Rio Grande do Sul published a decree establishing a new condition for the appropriation of deemed ICMS credits by manufacturers of electronic and IT products.

As from April 1, 2026, such taxpayers must execute an Agreement Instrument with the State, providing for investments in an industrial project as a requirement to enjoy the tax benefit. The other requirements already provided for in the legislation remain applicable.

The decree entered into force on the date of its publication, with retroactive effects as from January 1, 2026. The new requirement, however, does not apply to establishments that were already using the benefit on December 27, 2022.

Santa Catarina

Santa Catarina updates ICMS rules for agricultural inputs and changes credit system

On February 27, 2026, the State of Santa Catarina published a decree amending the ICMS Regulation with respect to transactions involving agricultural inputs, with effects as from March 1, 2026.

Among the changes, the transfer of accumulated ICMS credit balances arising from the deferral of the tax in internal transactions involving such inputs is now authorized. It also became possible to calculate the tax under the general credit and debit regime on the importation of certain agricultural inputs.

In addition, the rules on ICMS taxable base reduction applicable to transactions involving agricultural inputs were adjusted, in accordance with ICMS Agreement No. 100/1997 and Law No. 19,395/2025. The rule also creates new deferral cases and revokes the provision that previously allowed full maintenance of credits in such transactions.

Santa Catarina creates special regime for the use of accumulated credits linked to the Coopera Agro Program

On March 18, 2026, the State of Santa Catarina established a special regime allowing the transfer of accumulated ICMS credits under differentiated conditions for companies making contributions to the Coopera Agro SC Program, pursuant to Law No. 19,666/2025.

The normative act authorizes the granting of special limits for the use of such credits, especially those arising from the maintenance of tax credits related to transactions destined abroad, as well as exempt or deferred transactions.

The transfer limit will correspond to up to 50% of the amount invested in the program, provided that the minimum contribution is BRL 80 million, and will only be released after the effective completion of the investment. The use of the credits must occur in installments over 36 consecutive months.

Santa Catarina redefines criteria for granting ICMS credit transfer limits

On March 17, 2026, the State of Santa Catarina amended the procedures applicable to the granting of a special regime aimed at the transfer of ICMS credits, within the scope of TTD 489.

The rule updates the time criterion for recognition of investments, which will now be considered when made in the previous calendar half-year before filing the request, whether for renewal, amendment of the limit, or a new grant, replacing the previous system based on a fixed six-month period.

In addition, the situations involving investments capable of affecting the definition of the special limit were expanded to include those made by parent or subsidiary companies, provided there is direct or indirect equity participation corresponding to the entirety of the share capital. The act also details the characterization of indirect ownership, recognizing chain corporate structures with full control.

Santa Catarina restricts prohibition on ICMS benefits for imports of chemical products

On March 18, 2026, the State of Santa Catarina amended the rules applicable to ICMS taxation regimes on import transactions, restricting the previous prohibition on the enjoyment of tax benefits on the import of certain chemical products.

As a result of the amendment, the restriction now applies only when such products are intended for use in agriculture or livestock activities, allowing, in all other cases, access to the benefits provided by law.

The amendment produces effects as from March 1, 2026.

São Paulo

São Paulo denies ICMS credit to general warehouse receiving goods imported by a taxpayer from another State

In response to a tax ruling request published on March 9, 2026, the Finance and Planning Secretariat of the State of São Paulo (Sefaz/SP) clarified that, in direct import transactions carried out by a taxpayer established in another State, the ICMS due on importation generally belongs to the State where the legal recipient of the goods is domiciled or established, pursuant to STF Theme 520, even if customs clearance and warehousing take place in São Paulo.

In the case analyzed, in which a company located in Bahia imports goods, clears them through customs at the Port of Santos/SP, and ships them directly to a general warehouse in São Paulo, the Tax Consultancy concluded that ICMS must be paid to the State of Bahia. For this reason, São Paulo understood that there is no right to ICMS credit for the general warehouse located in São Paulo based on the amount paid on importation.

The response also emphasizes that, if the importer starts to carry out import, warehousing, and sale transactions on a habitual basis in the territory of São Paulo, it may be characterized as a habitual ICMS taxpayer in São Paulo, with the consequent obligation to register in the State Taxpayers’ Registry (Cadesp).

São Paulo tax authorities confirm revocation of the simplified procedure under the Nos Conformes Program for appropriation of accumulated ICMS credits

In response to a ruling request published on March 9, 2026, Sefaz/SP clarified that requests for appropriation of accumulated credits filed before the effectiveness of Ordinance SRE 50/2025, but not yet authorized by the tax authority, must follow the general procedure currently provided for in the legislation.

As a result, the simplified procedures previously applicable to taxpayers classified as “A+” and “A” within the scope of the Nos Conformes Program will no longer apply to proceedings still pending.

According to the tax authorities’ interpretation, Decree No. 69,808/2025 revoked the normative authorization that supported the simplified procedure, and Ordinance SRE 50/2025 removed the corresponding regulatory provision without establishing a transition rule. Accordingly, the procedures set forth in the current wording of Ordinance SRE 65/2023 will prevail, including with respect to requests previously submitted, provided that they are still pending authorization.

São Paulo excludes beverages and other products from the ICMS-ST regime

On March 18, 2026, the State of São Paulo published an ordinance excluding the application of the ICMS tax substitution regime to transactions involving several beverages, including beer, draft beer, sparkling wine, soft drinks, and mineral water.

Transactions involving ice cream and preparations for manufacturing ice cream in machines, stationery products, and construction materials and similar goods were also removed from the regime.

The ordinance enters into force on July 1, 2026.

São Paulo authorizes the application of partial ICMS suspension on importation together with other favorable treatments

In response to a tax ruling request published on March 27, 2026, Sefaz/SP concluded that the partial suspension of ICMS due upon customs clearance, granted by means of a special regime, may be combined with a tax benefit consisting of a taxable base reduction or the application of a reduced tax rate, provided that the requirements applicable to the benefited goods are complied with.

According to the tax authorities’ interpretation, there would be no cumulation of tax benefits, since the partial suspension of ICMS due upon customs clearance, granted by means of a special regime, is not characterized as an ICMS tax benefit.

Sefaz/SP also clarified that, in such cases, the ICMS due on importation must be calculated by applying the applicable tax rate to the relevant taxable base and, on the resulting amount, only the non-suspended portion of the tax must be paid. The São Paulo tax authorities also reinforced the procedures to be observed when completing the import NF-e in these cases.

São Paulo allows delivery of goods and materials to the future address of an establishment relocating within the State

In response to a tax ruling request published on March 24, 2026, Sefaz/SP authorized the delivery of goods and materials for use and consumption acquired by an ICMS taxpayer directly at the location to which the establishment will be transferred, even if that future address is under construction and located in another municipality within the State of São Paulo.

For this purpose, the NF-e issued by the supplier must indicate as recipient the establishment at the taxpayer’s current address, but must also indicate the future address as the place of delivery, with an express statement in the complementary information field that the establishment is in the process of relocation.

The response also clarifies that bookkeeping of the NF-e in the Entry Register Book may only take place once the change of address has been effectively completed, and must then be made extemporaneously, with the corresponding note.

Sergipe

Sergipe updates rules on symbolic return and redirection of goods

On March 16, 2026, the State of Sergipe amended the ICMS Regulation to govern the procedures applicable in cases of symbolic return due to refusal of delivery or inability to locate the recipient, as well as the subsequent shipment to a different recipient.

With effects as from May 4, 2026, the sender will be allowed to carry out such redirection only once, provided that the provisions established in the corresponding Sinief Adjustments are complied with.

In addition, the rule details the requirements for cancellation of the original transaction, requiring the issuance of an inbound NF-e with the specific purpose of a credit note and the proper completion of mandatory fields, including reference to the original NF-e and express indication of the reason for the return.

Salvador

Salvador regulates the implementation and taxation of electric vehicle charging stations

In a law published on March 26, 2026, the Municipality of Salvador established rules for the installation, operation, licensing, inspection, and taxation of electric vehicle charging stations.

For tax purposes, the rule provides that rapid electric charging stations intended for the provision of services to third parties will be classified under a specific category of electric vehicle charging services, without being characterized as electricity distribution activity, and will remain subject to the rules of the Municipal Finance Secretariat.

In addition, the law provides that digital platforms intermediating charging services are subject to ISS, considering as the taxable event the intermediation, booking, or collection of the charging service, including when involving digital payment methods or third-party processors.

The rule also requires such platforms to register with the Municipal Finance Secretariat, indicating the charging stations and related operators, under penalty of the applicable sanctions. The Executive Branch must regulate the form of collection, inspection, and calculation of the ISS levied on such platforms.

The law will enter into force 30 days after its publication.

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This material is for informational purposes only. Our Consumption Tax team is available to provide specific legal advice.