Brazil has enacted Complementary Law No. 225, creating a unified taxpayer code across federal, state, district, and municipal tax authorities. The law strengthens transparency and due process while introducing three compliance programs—Confia, Sintonia, and OEA—that reward compliant taxpayers with benefits and priority services. It also imposes stricter penalties on persistent debtors, including public disclosure and contract bans.

Brazil has enacted Complementary Law No. 225 of 8 January 2026, which introduces a new code governing taxpayer rights, guarantees, duties, and procedures in interactions with tax authorities at the federal, state, district, and municipal levels that are responsible for tax collection, supervision, regulation, and legal representation.

This Supplementary Law sets out the general rules governing the relationship between taxpayers and the tax administration, defining rights, guarantees, duties, and procedures. The law’s principles and procedures are mandatory nationwide and complement existing tax legislation.

The code introduces the following:

New taxpayer rights and duties defined

The code formally codifies taxpayer protections, including access to information, confidentiality, due process, and fair treatment. It also outlines taxpayer responsibilities, including accurate reporting, cooperation with audits, and adherence to filing and payment obligations.

Tax authorities bound by administrative standards

Tax administrations are now legally required to follow transparency, proportionality, and good-faith standards. The law also introduces procedural safeguards governing audits, notifications, and administrative decisions, aiming to reduce arbitrary enforcement and improve consistency.

Three new federal compliance programs introduced

Brazil has launched three federal compliance programs to reward high-performing taxpayers with tangible benefits:

  • Confia – Cooperative compliance: Designed for large taxpayers, Confia emphasises continuous engagement and internal control improvements, offering participants:
    • Personalised communication channels
    • Faster renewal of tax compliance certificates
    • Early dialogue on refunds, compensations, and interpretive guidance
  • Sintonia – Tax compliance incentive: Sintonia classifies taxpayers based on filing accuracy, payment timeliness, and declaration correctness, giving higher-rated participants priority in:
    • Refund processing
    • Service queues
    • Participation in consultative forums
  • OEA – Authorised economic operator: Focused on customs and supply-chain security, the OEA program rewards certified operators with reduced inspections, faster clearance, and deferred import tax payments.

Compliance seals offer tax benefits

Participants in Confia and Sintonia receive compliance seals that unlock further advantages, including:

  • CSLL tax discounts (starting at 1% after 12 months, increasing annually to a maximum of 3%)
  • Priority in administrative service requests
  • Tie-breaker preference in public procurement
  • Advance notice of potential infractions and a 60-day penalty-free correction window

Discounts are capped annually at BRL 250,000 in year one, BRL 500,000 in year two, and BRL 1 million thereafter.

New framework for handling non-compliance

The code distinguishes between ordinary non-compliance (e.g., late filings or payments) and persistent debtors, with the latter facing much harsher consequences.

Persistent debtor status targets chronic tax defaulters

A taxpayer may be classified as a persistent debtor if they demonstrate significant and repeated non-payment, including:

  • Tax debt of at least BRL 15 million and exceeding 100% of known assets
  • Repeated missed payments (4 consecutive periods or 6 periods within 12 months)
  • Failure to regularise without justification
  • Lack of guarantees or valid legal suspensions

Severe sanctions for persistent debtors

After being formally notified and given 30 days to regularise or contest the situation, persistent debtors may face harsh consequences under the new code.

These can include losing all tax benefits and CSLL loss carryforwards, being barred from public procurement and government contracts, and becoming ineligible for judicial recovery—potentially leading to bankruptcy conversion.

Their tax registration may be suspended or cancelled, and their status may be publicly disclosed in federal and state registries, alongside accelerated administrative action and intensified monitoring.

Complementary Law No. 225 took effect on 9 January 2026, with specific provisions for Confia and Sintonia entering into force 90 days after publication.