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In a landmark ruling with broad implications for Brazil’s industrial sector and tax environment, the Supreme Federal Court (STF) has declared that the municipal service tax (ISS) cannot be levied on contract manufacturing when materials are provided by the purchaser and the goods are intended for further industrialization or commercialization. The Court also set a … Read more
In a unanimous ruling, Brazil’s Supreme Federal Court (STF) upheld the constitutionality of a key provision in the country’s civil procedure rules, effectively allowing heirs to receive formal ownership of inherited assets without first having to pay the estate tax (ITCMD). This decision, issued in April 2025 in Direct Action of Unconstitutionality (ADI) 5.894/DF, has … Read more
On April 28, 2025, Brazil’s Office of the Attorney General (Advocacia-Geral da União – AGU) issued Normative Ordinance No. 174/2025, establishing procedures for submitting interpretive questions related to the country’s sweeping tax reform introduced by Constitutional Amendment No. 132/2023. The move is designed to promote legal certainty, improve predictability for businesses, and foster dialogue between … Read more
A new regulation issued by Brazil’s Federal Revenue (Instrução Normativa RFB No. 2.264/2024) introduces significant changes in the way PIS and Cofins contributions are calculated under the non-cumulative regime. While the measure is part of the broader transition to the future CBS tax system created by Brazil’s tax reform, one noteworthy provision directly benefits law … Read more
In a landmark decision with far-reaching implications for the industrial sector in Brazil, the Superior Court of Justice (STJ) unanimously ruled that companies are entitled to claim IPI (Tax on Industrialized Products) credits even when the final products they manufacture are tax-exempt or constitutionally immune—such as petroleum derivatives. This ruling, issued under the court’s repetitive … Read more
Brazil’s judicial system is a complex, independent, and constitutionally structured power, essential to the rule of law and the democratic order. The Federal Constitution of 1988 devotes an entire chapter to the Judiciary, outlining its organization, competencies, and guiding principles. This article presents a concise overview of Brazil’s Judiciary, helping international readers understand how justice … Read more
New restrictions under the 2025 Tax Reform may unlawfully limit benefits for people with disabilities, says civil society organization The Instituto Nacional de Direitos da Pessoa com Deficiência Oceano Azul has filed a constitutional challenge (ADI 7779) before Brazil’s Supreme Federal Court (STF), questioning recent tax reform rules that govern vehicle tax exemptions for people … Read more
Decision establishes that private pension and life insurance plan benefits are not subject to state inheritance tax In a binding ruling under General Repercussion Topic 1,214, Brazil’s Supreme Federal Court (STF) declared unconstitutional the levy of ITCMD — a state-level tax on inheritance and donations — on amounts received by beneficiaries of VGBL (Vida Gerador … Read more
Ruling reinforces protections for individuals with serious illnesses and ensures continued tax relief The Federal Court of Rio de Janeiro has ruled in favor of a retired taxpayer diagnosed with malignant neoplasm, granting full exemption from income tax withheld at source (IRRF) on his pension benefits. The decision was issued by the 12th Federal Court … Read more
Rule takes effect from 2024 and excludes retroactive application, preserving legal certainty and fiscal stability In a unanimous decision under General Repercussion Topic 1367, Brazil’s Supreme Federal Court (STF) reaffirmed that ICMS (state value-added tax) does not apply to the transfer of goods between branches of the same legal entity, even when located in different … Read more
