TAGD Advogados

Theme 1319/STJ, New Dividends Legislation: Advantages of JCP in Tax Planning

This article analyzes the STJ’s ruling in Theme 1,319 on the deductibility of interest on equity (JCP) for IRPJ and CSLL purposes. It also examines the impact of dividend taxation under Law 15.270/2025 and the renewed relevance of JCP as a tax planning tool.

Global Minimum Taxation is instituted in Brazil

This article outlines Brazil’s implementation of the OECD’s Global Anti-Base Erosion (GloBE) Rules through Law 15.079/2024. It examines the new minimum taxation framework, the additional CSLL, compliance requirements, tax incentives, and penalties applicable to multinational groups.

Mr. Olympia 2025 Individual Income TTaxation: na interesting case study

This article examines the Brazilian tax implications of prize money earned abroad through the case of bodybuilder Ramon Dino. It discusses worldwide taxation, foreign tax credits, income classification, and the reporting obligations applicable to Brazilian tax residents.

PGBL and VGBL Plans: Brazil’s Supreme Court Confirms that the Tax on Inheritance and Donations shou

This article analyzes the Brazilian Supreme Court’s decision confirming that VGBL and PGBL benefits received upon the death of the plan holder are not subject to inheritance tax (ITCMD). It also examines the succession and tax-planning advantages of these private pension structures.

Regularize to Advance: The 30% Tax and the Legal Challenge of Undeclared Cryptoassets

This article examines REARP, Brazil’s new asset regularization program, focusing on its application to cryptoassets. It discusses the program’s tax and criminal-law implications, the debated 30% cost of regularization, and the growing transparency and reporting requirements affecting cryptocurrency

Tax Challenges of Digital Inheritance

This article explores the legal and tax challenges of digital inheritance in Brazil, addressing the proposed Civil Code reform, recent court decisions, and the taxation of digital assets such as social media accounts, cryptocurrencies and other online assets.

The Limits of Classifying the Autonomous Storage System as an Independent Power Producer

Brazil’s debate on energy storage highlights the mismatch between classifying standalone storage systems as Independent Power Producers (PIEs).

From Regulatory Debate to Capacity Procurement: Energy Storage and Brazil's First Battery Auctions

Brazil's 2026 battery storage regulation marks a turning point: from legal uncertainty to binding rules, capacity auctions, and industrial policy — all at once.

Between Patches and Reforms: What Really Changed in the Electricity Sector in 2025

The coming biennium will be tasked with regulating, integrating and operationalising what was decided in 2025.

The Man Who Calculated and the Enigmas of the Electricity Sector in 2026

The challenges facing the Brazilian electricity sector demand less improvisation and more capacity for systematic analysis.

The Crisis Among Energy Retailers and the Urgency of the Supplier of Last Resort

Brazil's energy retail crisis exposes a critical regulatory gap: the Supplier of Last Resort exists in law but not in practice—just as the free market opens to millions of unprepared consumers.

How Net Metering Popularized Decentralized Solar Generation

The article examines how Brazil became one of the world’s leaders in solar energy through the adoption of Net Metering and supportive regulatory policies. It also analyzes the legal framework for distributed generation, international experiences, and current challenges related to grid capacity, regu

The Role of Energy Storage Systems in the Energy Transition

Energy Storage Systems (ESS) are essential to integrating renewable energy, improving grid flexibility, reliability, and efficiency. The article examines Brazil’s evolving regulatory framework, key tariff debates, and the need for clear rules to unlock investments and support the energy transition.