Fiscal subject related
General information
Brazil has implemented new invoicing requirements following the entry into force of Complementary Law No. 224/2025, which reduces federal tax benefits and introduces changes to PIS and COFINS treatment from April 1, 2026.
Under the new rules, transactions that were previously taxed at a zero rate are now subject to a reduced tax equivalent to 10% of the standard rate. This means companies must apply small but mandatory PIS (Social Integration Program) and COFINS (Contribution for the Financing of Social Security) charges when issuing electronic invoices (NF-e).
To ensure compliance, the Brazilian Federal Revenue Service clarified that businesses must:
- Use CST code 06 (Taxable Operation – zero rate) in e-Invoices (NF-e),
- Apply the adjusted tax rates (10% of the normal rate),
- Include a reference to Complementary Law No. 224/2025 in the additional tax information field.
Importantly, companies retain the right to claim tax credits related to these transactions, as they are still considered linked to zero-rated operations.
However, the update has created practical challenges, as this is the first time two tax treatments apply to the same transaction type. Some businesses are facing difficulties in invoice structuring and system configuration, with further technical adjustments expected from tax authorities.
Overall, companies must carefully update their invoicing systems and processes to ensure correct tax calculation and reporting, while monitoring ongoing guidance from the Federal Revenue Service and Tax Authority (SEFAZ).
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