The deductibility of losses arising from credit operations rests on three pillars: avoiding taxation on non‑existent wealth, preserving the reliability of taxable income (lucro real), and preventing abuse. From an economic standpoint, when a credit becomes irrecoverable—due to statute of limitations, insolvency, or definitive write‑downs granted in renegotiations—there is an effective reduction of net assets,…
The Pre-Filled Annual Income Tax Return represents one of the most significant advances implemented by the Brazilian Federal Revenue Service (Receita Federal do Brasil) in the process of filing the Individual Income Tax Return (IRPF). Its primary objective is to optimize tax compliance, minimize the occurrence of errors, and strengthen fiscal conformity. For the preparation…
The Office of the Prosecutor General (PGR) recently submitted to the Federal Supreme Court (STF) a legal opinion that may redefine how Brazil addresses so‑called pejotização and the jurisdiction for adjudicating disputes involving service‑provision contracts. According to the PGR, the STF has already established firm case law recognizing the constitutionality of alternative hiring models that…
The requirement that rural producers begin using the CNPJ as their exclusive tax identification number represents one of the most significant structural changes introduced by Brazil’s Tax Reform. Beginning in 2026, a transition period will allow the CPF and CNPJ to coexist. However, 2027 marks the start of full implementation, making the CNPJ mandatory for…
