Our team attended the meeting organised by the France-Brazil Chamber of Commerce (CCIFB-SP) with the Vice Governor of the State of São Paulo, Felicio Ramuth, on the 27th.
The agenda provided a clear overview of the State’s strategic projects for 2026, as well as a pipeline of opportunities in urban mobility, road infrastructure, social projects, water and energy. A significant volume of initiatives already under contract was highlighted, with dozens of auctions scheduled and approximately BRL 550 billion in planned investments.
The discussion, opened by Thierry Besse, brought together public authorities and representatives of the France–Brazil ecosystem, reinforcing a favourable environment for public-private partnerships, concessions and long-term investments. Potential developments of the European Union–Mercosur agreement were also addressed.
For GT Lawyers, closely monitoring this agenda is essential to advise clients on project structuring, infrastructure M&A transactions, and regulatory and tax matters, contributing to sound and executable decision-making in the State of São Paulo.
We thank the France-Brazil Chamber of Commerce (CCIFB) for the initiative, as well as the hosts and partners of the meeting for leading a high-quality and productive discussion.
Last Thursday, GTLawyers was pleased to attend the traditional Galette des Rois hosted by the France–Brazil Chamber of Commerce (CCIFB), an event that marks the start of the year for the Franco-Brazilian business community.
The evening brought together companies, executives, and professionals for valuable exchanges and networking opportunities. Our colleagues Cécile Verdeaux and João Antonio Cardoso were lucky enough to find the fève, adding a convivial touch to an evening dedicated to strengthening institutional ties.
We thank the CCIFB for this event, which continues to strengthen the bridge between France and Brazil in the business environment.
GTLawyers was delighted to participate in a special event at Mackenzie Presbyterian University: an international students’ pitch featuring students from Université Laval, with a sharp focus on business, strategy, and internationalization.
The students showcased a comprehensive market study and market entry strategy for Brazil for the Quebec-based startup MOS Racks. This presentation was the culmination of a course dedicated to navigating the business landscape in Latin America. It was a great opportunity to witness the students’ strategic thinking and their ability to bridge the gap between theory and practice by proposing actionable paths for international growth.
Representing GTLawyers, Cécile Verdeaux and Jeanne Puech were on hand to provide expert guidance and challenge the students on the legal frameworks of their proposals. We strongly believe that fostering a dialogue between academia and the professional world is vital for nurturing talent and building bridges across different regulatory and cultural environments.
We would like to extend our sincere thanks to Antoine Cauchon and the entire team at Mackenzie University for their warm welcome and seamless organization.
Congratulations to all the students for their high-quality work and compelling presentations. We look forward to continuing our support for initiatives that connect academic excellence with real-world market challenges.
Join us for: “INVESTING IN BRAZIL: Impact of the New Dividend Taxation and Financial Investment Opportunities”
We’ll explore the latest Brazilian tax developments and optimization strategies for your investments. A strategic opportunity to identify new France-Brazil opportunities.
Our experts:
Mestre Maxime Frémon (Sócio fundador da Frémon Avocats)
Mestre Estevão Gross (Sócio tributário do GTLawyers)
Data: 11 de dezembro de 2025
Horário: 14h (Horário de Paris)
Register and access the details via the link below: https://docs.google.com/forms/d/e/1FAIpQLSdIJKdtZ4DxrcnYjT6iHVe4tpK55ky-dFwnCiDl2HshbXWzgw/viewform?usp=publish-editor
The Tax Reform is bringing profound changes with the implementation of CBS and IBS. Is your company prepared?
Join us in this webinar with our associate Estevão Gross and Bianca Rodrigues from Pramex International to understand:
✔️ The main changes brought by CBS and IBS.
✔️ How these changes impact the services sector.
✔️ Strategies for adaptation and tax planning.
🗓 When? November 19, 2025, at 6:00 PM
📍 Hybrid format: In-person (GTLawyers) and online
Sign up for free at the link: https://forms.office.com/Pages/ResponsePage.aspx?id=P4y0RUBc8UKE1BPJQMeTQMdGbSvlNA5AjWoGZX5ZMP1UQzNMOTNUMFNFTzBOM1VSWExGMUI0TVIzRi4u
The changes brought by the tax reform are expected to have a significant impact on the real estate market.
Do you know what the main points of attention will be and how to prepare for them?
Our partner, Estevão Gross, will address this topic during the webinar:
October 21st, at 5 PM.
Register now through the link below to secure your spot!
https://lnkd.in/eiVHcax3
On September 10, GTLawyers, in partnership with French Tech São Paulo, will host a happy hour bringing together professionals from the technology and innovation ecosystem in São Paulo.
The event will take place at the Le Pain Quotidien Brasil venue, located in Jardins, and aims to create a space for exchange and connection between entrepreneurs, investors, legal market professionals, and representatives from emerging startups.
Data: 10 de setembro de 2025
Time: 7:00 PM to 11:00 PM
Location: Le Pain Quotidien, Alameda Lorena 1914 – Jardins, São Paulo
Participation is free, but registration is required, and spots are limited. Happy Hour | French Tech São Paulo | Câmara de Comércio França-Brasil
We are pleased to announce that Estevão Gross, a partner at our firm, will represent GTLawyers at an event promoted by the CCBC – Brazil-Canada Chamber of Commerce.
The central theme will be “The New Taxation: Impacts on International and National Business in Brazil”, a crucial debate to understand the effects of tax reform on the business environment.
Estevão will join a panel of renowned experts to share his insights and experience on the challenges and opportunities arising in this new legal and economic landscape.
We thank the CCBC for this excellent initiative and for the invitation!
Companies operating under the non-cumulative PIS and COFINS regime face a relevant strategic issue, constantly renewed by the uncertainties of Brazil’s tax landscape: how to utilize credits related to these contributions that were not recognized in their original period?
The non-cumulative PIS/COFINS regime, established by Laws No. 10,637/2002 and 10,833/2003, allows companies to recognize credits calculated on the acquisition of various goods and services, such as those used as inputs in production or service provision, which may be offset against PIS/COFINS liabilities for the relevant period. The legislation is clear in providing that credits not utilized in a given month may be carried forward to subsequent periods (Article 3, §4). This provision is explicit and leaves no room for ambiguity — the right to the credit is independent of the moment it is effectively used, provided that the five-year statute of limitations is observed.
Recently, however, the Brazilian Federal Revenue Service (Receita Federal) issued Consultation Ruling No. 8.003/2026, reinforcing prior interpretations according to which the late recognition of PIS/COFINS credits requires the amendment of tax filings, particularly the EFD-Contribuições, for each month in which the PIS/COFINS calculation was affected. This position aligns with prior rulings, notably Cosit No. 355/2017 and Cosit No. 90/2025. Such rulings reflect the prevailing administrative interpretation and serve as guidance for potential tax audits conducted by the Federal Revenue Service.
However, not all recent administrative decisions converge toward the requirement to amend tax filings. The Administrative Council of Tax Appeals (CARF), through Decision No. 3301-014.399 of the 3rd Chamber, issued on February 12, 2025, provided relevant arguments in the opposite direction. In that case, the taxpayer argued that, provided the certainty and liquidity of the credits were demonstrated, as well as their non-utilization in prior periods, the formal amendment of EFD/DCTF filings would not be required. The reporting judge upheld this position based on mathematical reasoning and principles of substantive law: the right to the credit is established by law and is not subordinated to merely procedural or ancillary obligations where the credit is demonstrably valid.
According to this decision, the recognition of late PIS/COFINS credits — provided they are not time-barred, have not been used in prior periods, and comply with proportional allocation rules — would be possible regardless of formal amendment of EFD filings, subject to proper evidence of the credit’s validity.
This understanding, however, is not settled within CARF, whose case law has, in the majority of decisions, required the amendment of ancillary obligations. Under this line of reasoning, the utilization of credits is intrinsically conditioned upon compliance with the relevant ancillary obligations, such as the EFD-Contribuições and DCTF. The rationale is that amendment is essential to preserve the consistency of the accrual accounting regime and the effectiveness of tax oversight, preventing the tax authorities from being confronted with extemporaneous information that has not been properly formalized.
This position emphasizes the accrual accounting principle: credits must be recorded in the period in which they arise, and late recognition without amendment would create accounting and administrative inconsistencies detrimental to tax supervision and legal certainty.
It should also be noted that Constitutional Amendment No. 132/2023 introduced the principles of simplicity and transparency into Brazil’s tax system. In light of this constitutional framework, which must guide both the drafting and application of tax laws, it could be argued that tax authorities should recognize the primacy of these principles over the complex, burdensome, and costly requirement to amend filings as a condition for validating late PIS/COFINS credits.
In any event, under the current scenario, the failure to amend ancillary obligations for the recognition of late PIS/COFINS credits may expose taxpayers to the risk of challenge. In such cases, however, robust legal arguments may be available in defense — particularly where the validity, liquidity, and prior non-utilization of the credits can be demonstrated.
Therefore, companies are advised to carefully assess their situation and seek specialized legal counsel in order to mitigate risks and define the most appropriate strategy for the utilization of late PIS/COFINS credits.
For further information on the subject, we remain at your disposal.
GTLawyers – Tax Team
We are proud to share the results of Análise Advocacia Mulher 2026, which reflect not only the recognition of the work carried out by our partners, but also a significant progression compared to the 2025 edition.
Tamy Tanzilli strengthened her presence in the ranking, increasing from 6 to 12 recognitions. Highlights this year include 1st place in International Trade and 1st place in Wealth and Succession Planning, in addition to rankings in areas such as Antitrust, Mergers and Acquisitions, Financial Transactions, Corporate Law, Real Estate, Commercial Contracts, Civil Litigation, and Regulatory Law. She is also ranked in the Specialized Services sector and in the State of São Paulo, where she has also improved her position compared to the previous year.
Anne-Catherine Brunschwig also recorded progress, moving up in the Specialized Services sector ranking and in the Rio de Janeiro regional ranking, while also earning a new recognition in Compliance. She is also once again listed among the most admired lawyers in the Digital field.
Carolina Moresco doubled her number of recognitions this year and showed strong progress in the São Paulo regional ranking. In 2026, she was recognized in Environmental Law and International Trade, and once again appears among the most admired lawyers in the Specialized Services sector.
These results reflect GTLawyers’ continued growth, the trust placed in us by our clients, and the consistent work of our partners across different areas of business law.
Congratulations to our partners for this new recognition!
