Impacts of LC 224/2025 on the Presumed Profit Regime
LC 224/2025 increased the presumed profit margins for revenues exceeding R$ 1.25 million per quarter, raising the tax burden and the complexity of the calculation.
LC 224/2025 increased the presumed profit margins for revenues exceeding R$ 1.25 million per quarter, raising the tax burden and the complexity of the calculation.
Complementary Law No. 214/2025 expanded the scope of IBS and CBS to cover onerous transactions based on economic substance, even in the absence of profit. In the context of cost sharing, the key issue is distinguishing pure reimbursement (payments made on behalf of and in the name of third parties, excluded from the taxable base) from the allocation of a company’s own costs, which may be characterized as the provision of intra-group services and, therefore, subject to taxation. Proper qualification and documentation will be essential to mitigate risks under the new regime.
The impacts of the Tax Reform on investment grants, highlighting that, despite the recent taxation by PIS/COFINS following Law No. 14,789/2023, these revenues were not included in the scope of IBS/CBS taxation. In this context, the debate arises regarding a potential revenue gap, as well as the legislator’s decision to restrict the new dual VAT solely to onerous transactions involving goods and services.
An analysis of the impacts of the new federal legislation on positive list medicines.
Tax Reform and Telecommunications: Understanding the Impacts of IBS, CBS, NFCom, Cashback, and the Fiscal and Operational Challenges in the Transition to the New Tax System.
With the Reform, companies are identifying credits to record in their accounting and tax systems for use after the reform comes into effect, since after that point it will no longer be possible to claim PIS and COFINS credits.
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