Machado

Brazil has affirmed that sales to the Amazonian free trade zone of Manaus must be equal to export transactions. Machado Associados' Ricardo Debatin da Silveira and Rogério Gaspari Coelho discuss the implications for exporters over the last five years.

Brazil’s Superior Court of Justice (STJ), which has the power to deliver final decisions regarding legality (constitutional matters are addressed by the Brazilian Supreme Court – STF), has reaffirmed that sales to the free trade zone of Manaus (FTZM) – which is in the state of Amazonas – must be equal to export transactions. Companies that have sold inputs or merchandise to the FTZM can therefore recover tax credits to foster exports, under the Special Regime for Reintegrating Tax Values for Exporting Companies (REINTEGRA).

Brazil's Federal Revenue Service provided important clarification regarding the concept of inputs for PIS and COFINS credits, but has still left much to discuss.