TozziniFreire | Tax Reform Event: What Lies Ahead?

TozziniFreire Advogados and PwC Brazil hosted an event on October 2, 2025, in São Paulo, bringing together lawyers, executives, and tax specialists to discuss the effects of the tax reform across the entire business production chain. Moderated by our partner Fernanda Pazello from the Tax practice, the first panel explored opportunities, risks, and impacts of the reform, highlighting that companies will move from a complex tax structure across various economic sectors to two taxes—one federal (CBS) and the other state and municipal (IBS).

Giancarlo Chiapinotto, partner and Tax leader at PwC Brazil for the southern region, and Maurício Guimarães, Tax director at PwC Brazil, emphasized the nuances of system projects within companies across all sectors of the economy. "The project is much more than a simple update; it needs to be assessed and integrated across all areas of the company,” said Chiapinotto. Examples were shared illustrating the broad technological challenges ahead, involving much more than just ERP systems—for instance, satellite systems for integration. A large volume of data will be affected by the reform, including inbound and outbound invoices. Emphasis was placed on preparing systems with new fields and the need for testing during the reform’s homologation period. "It’s important for companies to already allocate teams for testing,” Guimarães stressed.

Tatiana Midori addressed the new obligations in the technical notes and, regarding accounting, presented a comparison of calculations and rates between the current tax system and the one proposed under the Tax Reform, along with other practical details that will impact business operations.

Panel 2 was moderated by our partner Renata Emery, head of the Tax practice, and focused on the new Split Payment system with Rodrigo Fantinel, former Secretary of Finance of Porto Alegre and member of the IBS Pre-Management Committee (PCGIBS). Fantinel shared that he was involved in the initial development of the tax reform in Brasília and that its goal is to reduce tax evasion, delinquency, and lower the reference rate (up to 3%). He also provided practical examples involving purchases of goods with immediate payment and payment after 45 days.

Guilherme Nitschke, our partner in the Litigation practice, stated that "The new tax reform brings a degree of uncertainty regarding contracts; it is important to analyze the types of contracts, the market sector in which the company operates, and its position within it.” Nitschke offered a comprehensive overview of risks, clause typologies, and preventive measures, noting that the agribusiness sector will be among the most impacted by the reform.

TozziniFreire is a leading legal services organization in Latin America, operating in all areas of Business Law and with a relevant track record in serving local and foreign companies from the most diverse industries. With branch offices in several cities in Brazil (São Paulo, Rio de Janeiro, Brasília, Porto Alegre, and Campinas), including in New York, TozziniFreire strives to provide a unique standard of service quality and the same facilities to its clients throughout the country.

We have played a key role in many of the most significant transactions in the Brazilian market, contributing to the growth of the country's economy in recent decades. The relevance of our work has been recognized by specialized national and international publications, considering independent research interviews with professionals from the largest companies in the world. TozziniFreire and its partners are constantly referred to as leaders handling notable matters in the most varied business law practices. For further information, follow us on our social media channels and check out our website at www.tozzinifreire.com.br.