STF closes DIFAL dispute and consolidates case law: read the newsletter
Recent decisions by the Supremo Tribunal Federal and the Superior Tribunal de Justiça regarding DIFAL (Theme 1,266), the ICMS tax base, and parafiscal contributions reinforce a jurisprudential landscape that is increasingly restrictive toward taxpayers
Transfer Pricing in Chile: Tax Obligations before the SII
Understand Chile’s transfer pricing tax obligations, including the Master File, Local File, and deadlines for submission to the SII
Tax credits in class actions and ITBI immunity: read the newsletter
Recent decisions address limits on the Tax Authority’s actions, ITBI immunity, and the incidence of contributions on private pension plans
São Paulo shortens the period for the utilization of ICMS-ST credits on inventories
Amendment reinstates a 12-month credit utilization period, sets transition rules for the RPA, and requires a review of 2026 entries; see impacts and recommendations for companies
IPI excluded from PIS/Cofins, DIFAL, 13th salary during notice period, and attorneys’ fees: latest rulings by the STF and STJ
Check the recent rulings by the STJ and STF on PIS/Cofins credits, ICMS DIFAL, contributions on the 13th salary during the notice period, and attorneys’ fees
Decisions by the STF and the STJ on municipal interest and third-party contributions: check out newsletter
Check out the main tax rulings: the STF limits municipal interest to the Selic rate, while the STJ removes the cap on third-party contributions and upholds the use of surety bonds in tax enforcement, along with developments on tax-exempt dividends and payroll tax relief
Taxpayers set aside withholding income tax (IRRF) on donations and inheritances of fund units
Private Letter Ruling No. 21/2024 requires withholding income tax (IRRF) on the donation and succession of fund units, contrary to Law No. 9,532/1997
The “Sister” of the “Thesis of the Century” on the STF’s Docket
In February 2026, the Brazilian Supreme Federal Court (STF) will hear Theme 118, which discusses whether the ISS should be included in the PIS/COFINS tax base. Understand the thesis, the possible voting scenarios, and the risks of modulation
LC 224/2025: Reduction of Tax Incentives and Tax Impacts
Understand LC No. 224/2025: which tax incentives are subject to a linear cut, the taxes affected, new taxation parameters, effective dates, and the main points subject to judicial challenge
Could the exclusion of IBS/CBS from the base of legacy taxes be the “cousin” of the century’s thesis?
As the implementation of IBS and CBS approaches under the tax reform timeline, the debate arises over their inclusion in the calculation bases of ICMS, ISS and IPI; read more on our blog.
