Brazil legal and tax landscape undergoes significant shifts

Brazil is experiencing significant shifts in its legal and tax landscapes through various judicial rulings and proposed government policies.

The Superior Tribunal de Justiça (STJ) has issued several landmark decisions. The court ruled that accumulated loyalty program miles can be seized to settle debts, recognizing them as assets with economic value. Additionally, the STJ authorized the seizure of salaries to pay non-alimony debts in exceptional circumstances, provided the debtor's dignified subsistence is maintained. Regarding tax execution, the court established that redirection against an estate or successors is only permitted if the taxpayer was properly cited before death. Furthermore, the STJ is addressing whether the CPRB should be excluded from the PIS and Cofins calculation bases.

On the legislative front, the federal government is considering a new social security contribution aimed at companies with a high proportion of workers hired as legal entities (PJ). Proposed by Finance Minister Dario Durigan, the measure seeks to curb 'pejotização'—the practice of using PJ contracts to replace traditional employment relationships to avoid labor and tax obligations.

Meanwhile, the Supremo Tribunal Federal (STF) is reviewing cases regarding ICMS taxes on electricity subsidies for low-income consumers and the maintenance of tax benefits for Free Trade Zones in the North region.