Stronger controls. Better decisions.
This edition combines enforcement results published last week with two current tax priorities. The tax measures were announced earlier in September; they are not presented as new rules introduced this week.
- New enforcement results · 9 September
Labour enforcement: look beyond payroll records
On 9 September, Brazil’s Ministry of Labour and Employment reported that Operation Resgate VI rescued 479 workers from conditions analogous to slavery. The operation carried out 231 inspections during August. These are newly published enforcement results, not a new payroll filing obligation.
For companies buying services or building a Brazilian supplier network, the practical lesson is to review actual working conditions alongside employment records. A payroll reconciliation alone cannot establish whether conditions at a worksite are acceptable. This is a risk-management recommendation, not a finding about any particular supplier.
Suggested action: Review higher-risk service providers, clarify who monitors working conditions and define how concerns reach HR, procurement and legal teams. Keep an auditable record of the checks performed and the follow-up taken.
- Ongoing transition · Effective 1 September
Tax incentives: verify continuing eligibility
Receita Federal’s September guidance explains changes under IN RFB 2,341/2026 to monitoring corporate tax incentives. An adaptation period runs from 1 September to 31 December 2026, with communications seeking regularisation before the formal notification procedures begin in January 2027. That transitional treatment does not apply to entities classified as persistent tax debtors, or devedores contumazes.
The guidance highlights continuing requirements involving federal tax and FGTS compliance, Cadin, CNPJ registration and electronic tax communications. The adaptation period should not be treated as permission to disregard eligibility conditions.
Suggested action: Map the incentives actually used by each entity, identify the applicable requirements and assign responsibility for monitoring notices and resolving irregularities. For a new operation, verify eligibility before building an incentive into the business plan.
- Open settlement programme · Announced 4 September
Non-resident IRRF disputes: assess settlement options
Joint Notice PGFN/RFB 4/2026 offers a settlement route for qualifying disputes over Brazilian withholding income tax, IRRF, on capital gains and other income of non-resident investors. The official announcement, updated on 10 September, identifies an application deadline of 29 December 2026 at 19:00 Brasília time.
Eligibility requires an administrative or judicial dispute still awaiting a definitive decision when the application is made. Joining involves irrevocably acknowledging the included debts, withdrawing the related proceedings and waiving the associated legal claims. This is not a general reduction in withholding tax for foreign investors.
Suggested action: Ask tax counsel to check the specific dispute against the notice and compare settlement with continued litigation, including deposits, payment terms and the rights relinquished. Do not decide on a headline discount alone.
Source: Ministry of Finance announcement, updated 10 September 2026.
Reviewed 14 September 2026. Coverage: developments published 7–13 September, plus current measures announced earlier. Suggested actions are editorial recommendations. Applicability depends on the entity and underlying facts.