Brazil's Tax Reform Spurs Review of Asset Structures

Brazil's upcoming tax reform, described as one of the most significant changes to the country's tax system in decades, is prompting families, investors and businesses to reassess the legal structures that hold their assets. The reform highlights the need to examine the impact of changes to the inheritance and donation tax (ITCMD) and to ensure that existing holdings remain efficient, secure and adaptable to new rules.

At the same time, the Federal Revenue Service has issued a series of COSIT consultation solutions that clarify the interpretation of federal tax legislation. The guidance covers income tax on capital gains, Simples Nacional cash‑basis accounting, PIS/COFINS credit eligibility, and the conditions for refunds under the Perse program. These clarifications aim to reduce fiscal risk, improve compliance and identify opportunities for tax credit recovery.

Together, the reform and the new Receita Federal guidance encourage proactive tax planning and legal review to align asset structures with Brazil's evolving tax framework.