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  • João Paulo Muntada Cavinatto

    João Paulo Muntada Cavinatto

    Partner

  • Vinicius Jucá

    Vinicius Jucá

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  • Rafaela Canito

    Rafaela Canito

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August 07, 2026

17 min read

17 min read

Federal

National Congress extends the effectiveness of the Provisional Measure on simplified taxation of international postal shipments

On July 6, 2026, an Act of the President of the Board of the National Congress was published, extending for a further 60 days the effectiveness of Provisional Measure (MP) No. 1,357, of May 12, 2026 (MP 1,357/2026), which remains pending review by the National Congress.

Enacted on May 12, 2026, MP 1,357/2026 amends the Import Tax rates applicable to international postal shipments. Under the text still pending a vote, the rates may be reduced to zero for shipments of up to USD 50 and to 30% for shipments of up to USD 3,000, restricted to companies participating in the Remessa Conforme Program.

Federal Government regulates Brasil Semicon and updates Padis tax incentives

On July 15, 2026, Decree No. 10,615/2021 was amended to regulate the Brazilian Semiconductors Program (Brasil Semicon) and to update the rules of the Program to Support the Technological Development of the Semiconductor Industry (Padis).

Brasil Semicon aims to foster technological advancement and to strengthen the ecosystem for research, development, innovation, design, production, and application of semiconductor components, displays, and solar panels in Brazil. To this end, the decree structures the program around five pillars: tax simplification and tax relief, support for research and technology transfer, human resources training, financing of productive and technological infrastructure, and simplification of import and export procedures.

The amendments introduced to Padis cover machinery, equipment, parts and components, raw materials, packaging materials, computational tools, custom-made software, and services intended for the design and manufacturing of semiconductor components and displays.

In acquisitions carried out by legal entities qualified under Padis, the PIS and Cofins rates and, in the case of goods, also the rate of the Tax on Industrialized Products (IPI) may be reduced to zero, depending on the nature of the transaction.

The benefits also cover contracts for the licensing, development, implementation, customization, and updating of software used in production or in manufacturing management. Likewise, they may cover payments relating to patents, trademarks, technology transfer, supply of know-how, and technical assistance linked to the incentivized activities.

With respect to services rendered to legal entities qualified under Padis and intended for the incentivized activities, the decree reduces to zero the rates of Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL) levied on the taxable result of such services, subject to the conditions set forth in the regulation.

In addition, the rule creates the Brasil Semicon Management Council, which will be chaired by the Ministry of Development, Industry, Trade and Services (MDIC). The Council will also include representatives of the Ministry of Science, Technology and Innovation (MCTI), the Ministry of Finance, the Brazilian Development Bank (BNDES), and the Funding Authority for Studies and Projects (Finep).

MDIC and Suframa regulate the qualification of Industry 4.0 investments

On July 8, 2026, a Joint Ordinance of the Ministry of Development, Industry, Trade and Services (MDIC) and of the Superintendence of the Manaus Free Trade Zone (Suframa) was published, establishing requirements and procedures for the qualification of investments intended to raise the maturity level of production processes and sub-processes relating to Industry 4.0, pursuant to Decree No. 10,521/2020.

The rule sets out the guidelines under which companies in the Manaus Industrial Hub may allocate their investments in research, development, and innovation (RD&I) to the modernization and digital transformation of the sector.

Gecex maintains 12% Export Tax rate on petroleum

On July 10, 2026, a Resolution was published by the Executive Management Committee of the Foreign Trade Chamber (Gecex) maintaining, for a further 60 days, the 12% Export Tax rate on crude petroleum oils or oils obtained from bituminous minerals classified under heading 2709 of the Mercosur Common Nomenclature (NCM), originally established by Provisional Measure No. 1,340/2026

The Gecex Resolution was issued after the expiration of Provisional Measure No. 1,340/2026, which was not converted into law by the National Congress within the 120-day constitutional period and ceased to be effective on July 9, 2026.

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

Coana Ordinance approves procedural test for deferral of taxes on importation

On July 27, 2026, the General Coordination of Customs Administration (Coana) published an Ordinance establishing a procedural test relating to the deferral of the payment of taxes levied on the importation of goods and merchandise, pursuant to Complementary Law No. 225/2026 and RFB Normative Instruction No. 2,318/2026.

The purpose of the test is to assess the procedures for payment of the taxes linked to import transactions, the effectiveness of the Federal Revenue Service?s control systems over deferred payments, and the results of postponing tax collection.

Up to 30 operators certified under the OEA-C Reference modality may participate, upon formal expression of interest and subject to the selection criteria set forth in the ordinance.

During the test period, the Import Tax, PIS/Cofins, and IPI levied on importation, as well as the Cide-Fuels contribution, may have their payment deferred. Payment must be made by the 20th day of the month following registration of the Single Import Declaration (Duimp), or on the following business day.

The ordinance provides that customs clearance will be conditioned upon the absence of overdue debts relating to the deferred taxes, in addition to compliance with the other documentary and tax requirements. The test will begin 15 days after publication of the ordinance and will last 180 days, with a single extension for an equal period being permitted.

Federal Revenue Service allows PIS/Cofins credits on expenses with occupational safety technical reports

In a Private Ruling published on July 1, 2026, the General Coordination of Taxation (Cosit) of the Federal Revenue Service concluded that expenses relating to the preparation of occupational health and safety reports and programs required by labor legislation may be considered inputs for purposes of calculating PIS and Cofins credits under the non-cumulative regime.

The case involved a leather footwear manufacturer that engages legal entities specialized in occupational medicine and safety to prepare the Risk Management Program (PGR), the Occupational Health Medical Control Program (PCMSO), and the Technical Report on Environmental Working Conditions (LTCAT).

According to the Federal Revenue Service, such expenses meet the relevance criterion established by the Superior Court of Justice (STJ) in REsp No. 1,221,170/PR and incorporated into Cosit/RFB Normative Opinion No. 5/2018, as they arise from obligations set forth in the Consolidation of Labor Laws (CLT).

Federal Revenue Service amends CNPJ registration rules

On July 10, 2026, the Federal Revenue Service published a Normative Instruction amending the regulation of the National Register of Legal Entities (CNPJ), as well as introducing new requirements and rules relating to the register.

Criteria relating to the registration status of representatives and of members of the Register of Partners and Administrators were amended, providing for situations involving an irregular registration status in the Individual Taxpayer Register (CPF) or in the CNPJ.

In addition, situations relating to the identification of the legal entity and to the consistency of the information declared in the register were detailed, such as, for example, the indication of an email address linked to another company and inconsistencies between the economic activity, legal nature, declared purpose, and identification of the legal entity.

The new rules entered into force on the date of publication of the Normative Instruction.

Federal Revenue Service regulates jurisdiction over taxpayers under Confia

On July 10, 2026, the Federal Revenue Service published an Ordinance regulating the national jurisdiction over taxpayers admitted to the Cooperative Tax Compliance Program (Confia), established by RFB Normative Instruction No. 2,295/2025.

The rule supplements the regulation of the program by defining the Federal Revenue Service units responsible for monitoring and managing participating taxpayers.

Under the Ordinance, jurisdiction over Confia taxpayers will be exercised, on a national basis, by the Federal Revenue Service Offices in Manaus, Salvador, and Florianópolis and by the Special Tax Audit Operations Office in São Paulo (Deope/SPO), in accordance with the sector allocation set forth in an annex. These units will be responsible for taxpayer service, registration, collection, enforcement, tax audit, and monitoring activities in respect of the taxpayers admitted to the program. The rule preserves, however, the powers of the Financial Institutions Office in São Paulo (Deinf/SPO) and of the Large Taxpayers Office in Rio de Janeiro (Demac/RJO) with respect to taxpayers already under their jurisdiction.

Federal Revenue Service defines PIS and Cofins calculation base for fixed-odds betting operators

On July 24, 2026, the Federal Revenue Service published a Cosit Private Ruling addressing the determination of the PIS and Cofins calculation base in the case of revenues from the provision of fixed-odds betting lottery services in physical or virtual form.

The advisory division concluded that the gross revenue of such transactions corresponds to the so-called Gross Gaming Revenue (GGR), calculated on the basis of the proceeds collected from bets, after deduction of the amounts allocated to the payment of prizes.

The private ruling also clarifies that amounts that merely pass through the legal entity?s accounting records and belong to third parties, including mandatory allocations provided for by law, do not form part of the concept of gross revenue. The interpretation was partially bound to Cosit Private Ruling No. 170/2021.

Federal District authorizes fuel distributors to transfer ICMS credit balance

On July 9, 2026, the Federal District published a decree amending the ICMS Regulation to allow fuel distributors to transfer to petroleum refinery establishments, or to their bases located in the Federal District, the ICMS credit balance accumulated as a result of the appropriation of a deemed tax credit on transactions involving B diesel oil intended for companies holding concessions or permits for public passenger transportation.

The procedure must be formalized through the issuance of an adjustment Electronic Invoice (NF-e), with purpose code 3, Transaction and Service Tax Code (CFOP) 5.601, and Tax Situation Code (CST) 90.

The transfer is conditioned upon the tax compliance of the sending distributor, evidenced by the absence of debts enrolled in the Federal District?s active debt registry and by good standing in the Federal District Tax Register (CFDF).

Amazonas

Amazonas expands tax incentive for energy storage modules

On July 23, 2026, the State of Amazonas published a decree granting a 100% incentive credit (crédito estímulo) for accumulator modules with lithium-ion electrochemical cells intended for electricity storage stations, classified under NCM code 8507.60.00, corresponding to lithium-ion accumulators. The incentive does not cover modules used in systems classified under NCM code 8504.40.40, relating to uninterruptible power supply equipment (no-break). The decree also established the deferral of the assessment and payment of ICMS on the importation of raw materials and secondary materials used in the manufacturing of such products.

In order to benefit from the incentives, companies must request the State Secretariat for Economic Development, Science, Technology and Innovation (Sedecti) to issue a Technical Inspection Report. The measures apply retroactively as from April 14, 2026 and will produce effects through April 13, 2029.

Ceará

Ceará establishes policy to encourage the implementation of energy storage systems and data centers

On July 16, 2026, the State of Ceará published a law establishing the State Policy to Encourage the Implementation of Battery Electricity Storage Systems and of data centers and data processing centers in the State.

Among other measures relating to environmental licensing and to the implementation of such projects, the law authorizes the Executive Branch to grant ICMS tax treatment, including through deferral or tax relief on the acquisition of machinery, equipment, and components intended for fixed assets.

The granting of such tax treatment is not automatic and is conditioned upon the execution of an agreement, or adherence to an agreement in force, within the scope of the National Council for Fiscal Policy (Confaz), pursuant to Federal Complementary Law No. 24/1975, as well as upon compliance with fiscal responsibility legislation.

Goiás

Goiás expands granted ICMS credit under ProGoiás in cases of fortuitous event or force majeure

On July 10, 2026, the State of Goiás published a law expanding the application of the granted ICMS credit (crédito outorgado) available to industrial establishments qualified under ProGoiás.

The benefit may cover transactions involving products manufactured on a toll basis, by order and on behalf of the beneficiary establishment, at another establishment of its own or of a third party located in another state, in the event of a fortuitous event or force majeure preventing manufacturing in Goiás.

The application of the granted credit in such cases will depend on the execution of a special regime agreement and may occur for a period of up to six months, counted from the occurrence of the event, extendable once for an equal period.

The amendment also covers fortuitous events or events of force majeure occurring in the twelve months prior to July 10, 2026, provided that they still prevent manufacturing in Goiás on the date of execution of the special regime agreement. In such cases, the initial six-month period will be counted from publication of the law.

Goiás establishes procedures for voluntary regularization of taxes

On July 14, 2026, the State of Goiás published a normative instruction establishing the procedures for the regularization of taxes voluntarily declared by the taxpayer before the commencement of any tax audit procedure.


The declaration must be filed through the Digital Process Platform (PDP), by completing the Debt Declaration Form ? Voluntary Regularization, accompanied by the list of declared debts, the supporting documents necessary for calculating the tax, and the indication of the payment method, whether in a single payment or in installments.

In the case of full payment in a single installment, the principal amount will be increased by default interest. In the case of installment payment, default interest and a late-payment penalty will apply, and the taxpayer must issue the Tax Credit Installment Payment Agreement in the E-parcelamento system and formalize the installment plan within 30 days, counted from the generation of the Voluntary Regularization Administrative Proceeding.

The procedure does not apply to taxes that are subject to self-regularization or that have been previously declared in the situations expressly indicated by state legislation.

Minas Gerais

Minas Gerais amends rule on electronic presentation of the DACTE

On July 22, 2026, the State of Minas Gerais published a decree revoking a provision of the ICMS Regulation relating to the electronic presentation of the Auxiliary Document of the Electronic Bill of Lading (DACTE).

The revoked provision restricted the electronic presentation of the DACTE where the Electronic Bill of Lading (CT-e) was issued under contingency procedures using the Security Form for Printing of Auxiliary Documents of Electronic Tax Documents (FS-DA), even if the Electronic Manifest of Tax Documents (MDF-e) was issued.

With the revocation, this restriction no longer applies. The amendment entered into force on July 22, 2026

Paraná

Paraná regulates individual settlement for exporters affected by the United States tariff increase

On July 9, 2026, the State of Paraná published a decree regulating the conditions for entering into an individual settlement aimed at resolving disputes involving companies established in the State of Paraná that carry out export transactions and have been affected by the tariff increase imposed by the Government of the United States of America.

In addition to the requirements set forth in state legislation on settlements, the request must be accompanied by evidence that the company is established in Paraná and carries out export transactions; that it exported to the United States in the 12 months prior to August 6, 2025, in an amount exceeding 10% of its total revenue; and that there is a direct correlation between the tariff increase and the financial difficulties faced.

For purposes of verifying these requirements, the amount of exports and the total revenue will be calculated based on the amounts recorded in the invoices issued by all of the company?s establishments located in Paraná.

The request must be filed within 60 consecutive days, counted from publication of the decree, and must also comply with the other requirements and conditions set forth in state legislation.

Rio de Jeneiro

Rio de Janeiro reinstates expanded FOT rules and exceptions

On July 6, 2026, the Legislative Assembly of the State of Rio de Janeiro published the rejection of vetoes to provisions of Law No. 11,071/2025, reinstating amendments to the Temporary Budget Fund (FOT) system. Among the reinstated measures is the application of an additional percentage of 8.18% on transactions involving goods and merchandise intended for certain research, exploration, or production activities relating to oil and natural gas, which raises the total additional FOT burden to 18.18% in cases such as blocks in the exploration phase and small-production fields.

The changes have produced effects since July 6, 2026 and require the affected companies to review the qualification of their tax incentives and the percentages used in the payment of the FOT.

Rio de Janeiro restricts transfer of deemed ICMS credit in transactions involving marine diesel oil

The Finance Secretariat of the State of Rio de Janeiro (Sefaz/RJ) published a Tax Ruling clarifying the rules for the transfer of the deemed ICMS credit in transactions involving marine diesel oil subject to the single-phase regime.

According to Sefaz/RJ, the supplier of marine diesel oil may transfer the deemed credit to the taxpayer responsible for the payment of ICMS under the single-phase regime, by issuing an NF-e, provided that the formalities set forth in the legislation are observed.

The ruling clarifies, however, that such transfer may not be made indiscriminately to any refinery located in the State. The credit may only be transferred to the taxpayer that, in the specific transaction, is responsible for the payment of ICMS and is part of the same circulation chain of the fuel that gave rise to the benefit.

In support of this position, Sefaz/RJ emphasizes that the single-phase regime requires a link between the tax credit and the transaction that gave rise to it, and that the autonomous circulation of credits between refineries unrelated to the respective fuel marketing chain is not permitted.

Rio Grande do Norte

Rio Grande do Norte amends rules applicable to commercial transactions, toll manufacturing, and tax substitution

On July 22, 2026, the State of Rio Grande do Norte published a decree amending the ICMS Regulation to govern various transactions.

As from September 1, 2026, transactions involving the circulation of goods carried out through autonomous markets, vending machines, and collaborative stores must comply with the procedures to be established in a specific act of the State Finance Secretary.

The decree also amended the rules for the issuance of tax documents in toll manufacturing transactions in which the goods acquired are delivered by the supplier directly to the manufacturing establishment, without passing through the purchaser’s establishment. Among other requirements, the Electronic Invoices issued by the supplier must state the details of the establishment where the products will be delivered and indicate that the goods are intended for manufacturing, and the corresponding Auxiliary Document of the Electronic Invoice (Danfe) must accompany the transport.

In addition, with effects as from July 1, 2026, certain shipments of goods classified under the Tax Substitution Specifier Codes (CEST) indicated in the decree, when originating from or destined for the State of São Paulo.

São Paulo

Sefaz/SP clarifies issuance of NF-e for return of leased assets after corporate succession

On July 13, 2026, the Finance and Planning Secretariat of the State of São Paulo (Sefaz/SP) published a Response to a Tax Ruling Request concerning the issuance of an NF-e for the return of leased assets following a corporate restructuring.

The case analyzed by the advisory body involved a company engaged in the leasing of machinery and equipment whose establishment was merged into another company of the same economic group.

In this context, Sefaz/SP concluded that, once corporate succession with operational continuity is established, the successor company assumes the pending transactions linked to the transferred establishment. Accordingly, it must be indicated as the recipient in the NF-e for the return of the leased assets, even if the original shipment invoice was issued in the name of the succeeded company.

With respect to the return of assets sent for repair, the advisory body found that the request was inadmissible due to the absence of sufficient factual elements for the analysis of the matter, such as the identification of the party responsible for the repair and the nature of the asset involved (fixed asset or merchandise).

This position is relevant for taxpayers involved in corporate reorganizations, especially where there are transactions still in progress that were initiated before implementation of the restructuring, contributing to greater legal certainty in the tax treatment of such flows.


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


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