Brazil's Federal Revenue issues tax rules for innovation prize payments

The Brazilian Federal Revenue Service (Receita Federal) released Solution of Consultation Cosit No. 91 on June 23, 2026, clarifying that prizes granted to employees for innovation ideas are excluded from the INSS contribution base when the payments are liberal, not contractual, and reflect performance above ordinary expectations. The guidance applies to cash, goods or services awarded under internal idea‑submission programs, provided the employer can document the evaluation criteria and demonstrate that the amounts are not regular remuneration.

Separately, the Superior Court of Justice (STJ) will rule on whether commercial discounts and bonifications should be included in the calculation base for PIS and Cofins contributions. The decision, taken under the repetitive‑resource procedure, will bind courts nationwide and could affect the tax burden of thousands of firms that routinely use discounts and free‑product incentives in sales negotiations. A ruling that includes these amounts would raise taxes, while exclusion could allow companies to recover previously paid contributions.