STF has majority in favor of taxing profits of foreign subsidiaries by Brazilian companies
oglobo27 August 2026 at 19:46
The Supreme Federal Court formed a majority to allow the collection of IRPJ and CSLL on profits obtained by Brazilian companies through subsidiaries abroad, even when those subsidiaries are in countries with double taxation treaties. Six ministers voted in favor, including Gilmar Mendes (who opened the dissent), Alexandre de Moraes, Flavio Dino, Carmen Lucia, Cristiano Zanin and Kassio Nunes Marques. The virtual plenary session trial ends this Friday, with only the vote of presiding justice Edson Fachin pending. The case involves a dispute between the Federal Government and Vale, with an estimated impact of R$ 22 billion for the government in case of defeat, according to the 2026 LDO.
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