STF and STJ’ decisions regarding ICMS are the focus of this Tax Newsletter

Among the tax law news from the past month are STF decisions on retroactive ICMS, habitual tax debtors, and STJ rulings on ICMS DIFAL
National Treasury issues favorable opinion to taxpayers with respect to Workers’ Food Program

The opinion acknowledges that decree-based limitations on the PAT (Worker’s Food Program) should not prevail; the law guarantees companies the right to a tax deduction
Federal Revenue Service publishes new notices with simplified conditions for settling tax debts

The Federal Revenue Service has published two new public notices for adhesion-based settlements, in which benefits may be granted without the need for individual negotiations with the tax authorities. Regarding Public Notice No. 5/2025, the Federal Revenue has conditioned the granting of discounts and the use of tax loss carryforward credits on the degree of […]
Provisional Executive Order limits judicial tax debt offset and restricts tax benefits

The rule has the same enforcement as a law and must be voted by Congress within 120 days, under penalty of effectiveness loss
Liberal Party files Direct Action against Provisinal Measure of tax incetives; check the newsletter

Tax Law newsletter also includes: STJ removes restrictions on the deduction of PAT; and Early execution of guarantee is prohibited
Federal Government changes taxation rules on ICMS benefits with MP 1185

MP’s text will move on to presidential sanction, coming into force as Law in January 2024; the primary target of this measure is the ICMS tax benefits
New judgments at Superior Court of Justice about PIS, COFINS, and ICMS-ST

The Court concluded the judgment of Special Appeals questioning whether the State VAT due in Tax Substitution (ICMS-ST) should be included in contributions
STJ authorizes PIS/Cofins credits on substitute State VAT (ICMS-ST); check the newsletter

The 1st Panel of STJ recognized the right to claim PIS/Cofins tax credits on amounts paid as State VAT of tax substitution ICMS-ST; check the newsletter