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Maria Rita Ferragut

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Maria Rita Ferragut joined the Firm in 2019. With 25 years of experience, she is the lead partner of the Tax Law group, acting with a focus on Tax Litigation, at the federal, state and municipal levels.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.
In Tax

Brazil: Internal Revenue Services publishes public notice for special settlement agreement of tax debts in administrative litigation

by , and 2 Mins Read

On 19 March 2024, the Public Notice of Special Settlement Agreement No. 1/2024 was published, which provides for the opening of the Zero Litigation Program 2024, a new special settlement agreement for tax debts in administrative litigation within the scope of the IRS of Brazil, the value of which, per litigation, is up to BRL 50,000,000.00. Discounts and payment terms will be determined according to the degree of recoverability of the debts. The deadline for joining the Program is 1 April 2024 to 31 July 2024.

In Tax

Brazil: The RFB has issued IN RFB No. 2184/2024 regulating the thesis transaction regarding the Investment Subsidies Taxation

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On 3 April 2024, the Federal Revenue of Brazil (RFB) issued Normative Instruction No. 2184/2024, which regulates the tax transaction provided in Article 14 of Law 14789/2023. This transaction aims to encourage companies to pay IRPJ and CSLL (corporate income taxes), resulting from the exclusion of investment subsidies made in disagreement with Article 30 of Law No. 12973 of 13 May 2014, provided that they have not been subject to assessment.

In Tax

Brazil: Tax Reform approved by the Congress

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On 16 December 2023, the House of Representatives approved the bill of Tax Reform, based on PEC 45 (Constitutional Amendment Bill), in the final round after the Senate’s approval.

The final wording was published on 21 December 2023 (Constitutional Amendment No 132/23).

In Tax

Brazil: Law no. 14,689/2023 – The return of the tie-breaking rule in favor of the Tax authorities

by , and 4 Mins Read

On 21 September 2023, Law no. 14,689/2023 was enacted as a result of the sanction, with vetoes, by the Vice-President of the No. 2,384/2023, with the purpose of disciplining the proclamation of judgment results in the event of a tie vote within the scope of the Administrative Council of Tax Appeals (CARF), among other measures connected to tax litigation and the transaction in the collection of credits by the Federal Treasury.

In Tax

Brazil: Senate approves the return of the tie-breaking rule in favor of the Tax authorities at the administrative level (CARF)

by , and 3 Mins Read

On 30 August 2023 Bill No. 2,384/2023 was approved, with the purpose of disciplining the proclamation of judgment results in the event of a tie vote within the scope of the Administrative Council of Tax Appeals (CARF), among other measures connected to tax litigation and the transaction in the collection of credits by the Federal Treasury.

In Tax

Brazil: House of Representatives approves the return of the tie‑breaking rule in favor of tax authorities

by , , , , , , , , and 4 Mins Read

On 7 July 2023, the Substitutive Amendment to Bill No. 2,384/2023 was approved, with the purpose of disciplining the proclamation of judgment results in the event of a tie vote within the scope of the Administrative Council of Tax Appeals (CARF), among other measures connected to tax litigation and the transaction in the collection of credits by the Federal Treasury.