We would like to remind you that the deadline for filing the Brazilian Corporate Income Tax Return (Escrituração Contábil Fiscal – ECF) for the 2025 calendar year is July 31, 2026.

In this context, we would like to highlight several areas that require special attention:

Block X – Transfer Pricing

• Transfer Pricing rules were updated by Law No. 14,596/2023 and Brazilian Federal Revenue Service Normative Instruction No. 2,161/2023.

• Transfer Pricing analyses conducted under the new legislation must be properly reflected in the ECF.

• It is essential to review the methods applied, any required adjustments, and supporting documentation to avoid inconsistencies and potential tax assessments.

Block X – Worldwide Taxation

• Brazil’s Worldwide Taxation Regime requires Brazilian legal entities with investments in foreign companies to recognize the results of those foreign entities for Corporate Income Tax (IRPJ) and Social Contribution on Net Income (CSLL) purposes.

• Information regarding the foreign investee company, including its balance sheet and income statement, must be reported in Block X of the ECF.

• It is critical to review the information being reported, the adjustments made, and any applicable offsets or consolidations to ensure proper reporting in accordance with Brazilian tax legislation.

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Block W – Country-by-Country Report (CbC Report)

• Companies that are part of multinational enterprise groups with consolidated revenue exceeding the applicable threshold must submit a Country-by-Country (CbC) Report.

• Proper completion of this filing ensures transparency and compliance with international reporting standards.

Our Solution

We offer a specialized review service for Blocks X and W of the ECF, ensuring:

• Compliance with current legislation;

• Mitigation of tax risks;

• Timely filing within the statutory deadline.

Please contact our team through the available chat or by email at info@drummondadvisors.com to schedule a review and ensure full compliance with this reporting obligation.

Written by Hanna Lauar, Senior Associate at Drummond Advisors