Articles from our daily lives

Tax Reform 2027: Where the Real Margin Gains and Losses Lie Under CBS

The discussion about the 2027 tax reform usually starts with the tax rate. However, for most companies, this will not be the most important issue.

Tax Reform

LC 224/25 and Its Impacts on the Pharmaceutical Sector: Price Increases and the Principle of Essentiality

LC 224/25 reduces tax incentives for medicines by limiting presumed PIS/Cofins credits, increasing the sector’s effective tax burden. This may lead to higher drug prices, especially in a market already above inflation. The change also raises concerns about unequal treatment of essential goods, particularly medicines versus food.

Tax Reform

Oil Sector: STJ Decision Reaffirms the Right to ICMS Credits on Strategic Inputs

An STJ decision reaffirmed the legality of ICMS tax credits on drilling fluids in the oil sector, emphasizing the essentiality and relevance criteria for classifying strategic inputs in Brazilian tax law.

Tax Reform

Debit and Credit Notes in the Tax Reform and the Innovations of SINIEF Adjustment 49/2025

The Debit and Credit Notes introduced by SINIEF Adjustment 49/2025 formalize tax adjustments under the new IBS and CBS system, ensuring traceability, transparency, and compliance, while also affecting ICMS and requiring attention to state regulations.

Tax Reform

CARF removes requirement for amended EFD-Contributions to claim extemporaneous PIS/Cofins credits

CARF ruled that the amendment of EFD-Contributions does not constitute a requirement for the use of extemporaneous PIS/Cofins credits within the SPED framework, thereby limiting the scope of Precedent No. 231.

Tax Reform

Cost Sharing and the Incidence of IBS and CBS

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.

Tax Reform