Impacts of the Tax Reform on the Manaus Free Trade Zone in the Electro-Electronic Sector: Challenges and Perspectives

Bárbara Fonseca Felizatto Bocucci; Raissa Alvares de Matos Miranda

DOI: 10.22167/2675-6528-202602702

Article derived from a Final Course Work (TCC), with content based on the student’s original work and adapted to the editorial format of the E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.

Abstract

The Manaus Free Trade Zone (ZFM) represents a pillar of Brazilian regional development, and the electro-electronic sector plays a strategic role in its Industrial Pole. The study analyzed the impacts of the tax reform on the electro-electronic sector installed in the ZFM, focusing on changes in the incentive regime, industrial competitiveness, and job creation. The research employed a qualitative and quantitative approach, with documentary analysis of the relevant legislation (EC No. 132/23, LC No. 214/25, LC No. 227/26, RCBS, RIBS) and public data from the Superintendence of the Manaus Free Trade Zone (SUFRAMA), especially from the Manaus Industrial Pole Performance Indicators Notebook for 2025 and the first two months of 2026. The results revealed that the tax reform did not suppress the ZFM’s favored treatment, but rather reconstructed it through mechanisms such as suspension, conditional exemption, zero rate, and presumed credits of IBS and CBS, in addition to the selective preservation of IPI. The electro-electronic complex, including IT goods, invoiced R$ 86.5 billion in 2025, corresponding to almost 38% of the PIM’s invoicing, and concentrated 47,630 jobs. An asymmetry was identified in the presumed credits between the IBS and CBS regulations, a relevant normative finding for the sector. It was concluded that the reform preserved the legal basis of the ZFM’s competitive advantage, but transferred part of the model’s stability to the regulatory and operational stage, requiring institutional coordination, legal certainty, and adaptation strategies for maintaining competitiveness.

Keywords: CBS; Industrial competitiveness; IBS; Manaus Industrial Pole; SUFRAMA.

1. Introduction

The Manaus Free Trade Zone (ZFM) was conceived as a public policy for regional development, aiming at the interiorization of economic activity and the productive integration of Western Amazonia. Its structure was initially regulated by Decree-Law No. 288 of 1967 (Brazil, 1967), and later incorporated by Article 40 of the Transitory Constitutional Provisions Act (ADCT) of the 1988 Federal Constitution. By virtue of Constitutional Amendment No. 83 of 2014 (Brazil, 2014), the ZFM incentives were extended until 2073, providing an extensive temporal horizon for economic planning and the development of a consistent regional industrial policy.

Over the past few decades, the ZFM model has consolidated itself as one of the main instruments for the deconcentration of industry and production in the Country, supported by a differentiated regime of tax incentives and requirements for productive, technological, and regional counter-performance. These benefits include exemption from the Tax on Industrialized Products (IPI), reduction of the Import Tax (II) on raw materials and capital goods, and differentiated treatment of federal, state, and municipal taxes, conditioned on compliance with the Basic Production Processes (PPB). The economic relevance of the ZFM remains high, with the Manaus Industrial Pole (PIM) bringing together around 600 industries and achieving a turnover of R$ 229 billion in 2025 (SUFRAMA, 2026b). Recent literature highlights that the effects of the ZFM transcend the merely fiscal dimension, contributing to environmental preservation and the containment of predatory economic pressures on the Amazon rainforest (Ribeiro; Marinho; Carvalho, 2024).

Among the various segments that make up the productive arrangement of the PIM, the electro-electronic sector occupies a strategic position of expressive relevance. This sector, which includes the manufacturing of televisions, air conditioners, mobile phones, and IT goods, concentrates chains of greater technological intensity and presents greater sensitivity to tax and logistical costs. In 2025, the electro-electronic complex, including IT goods, had a turnover of R$ 86.5 billion, which represented almost 38% of the PIM’s total turnover, and concentrated 47,630 jobs, equivalent to 36.12% of the average workforce in the hub (SUFRAMA, 2026b).

The magnitude of these numbers shows that any change in the competitiveness of the electro-electronic sector tends to generate significant economic and social effects in the region. In this context, the Brazilian tax system underwent a profound restructuring with the approval of Constitutional Amendment No. 132, of 2023 (Brazil, 2023). This reform proposed the replacement of five consumption taxes with a simplified system, based on the Tax on Goods and Services (IBS), with state and municipal competence, the Social Contribution on Goods and Services (CBS), with federal competence, and the Selective Tax (IS). The transition to the new system is occurring gradually between 2026 and 2033.

In the specific case of the ZFM, the tax reform required careful harmonization between the new system and the constitutional protection historically afforded to the model. Article 92-B of the ADCT, introduced by EC No. 132/2023, stipulated that the laws establishing the new taxes preserve the competitiveness level already granted to the ZFM. Complementary Law No. 214 of 2025 (Brazil, 2025), and subsequent regulations (LC No. 227/2026, Decree No. 12,955/2026, CGIBS Resolutions No. 6/2026 and 14/2026) rebuilt the favored treatment through mechanisms such as suspension, conditional exemption, zero rate, and presumed credits of IBS and CBS, in addition to the selective preservation of IPI in cases defined by law.

Although the reform did not eliminate the preferential treatment of the ZFM, it transferred part of the model’s stability to the regulatory and operational stage, introducing a new, more complex legal architecture. The effectiveness of the competitiveness preservation mechanisms now depends on regulatory clarity, control efficiency, timeliness of crediting, and institutional coordination among the various bodies involved. This transition raises challenges related to operational legal certainty, heterogeneity of intra-sectoral impacts, and the need for strategic adaptation by companies.

Given the economic and social centrality of the electro-electronic sector for the ZFM and the complexity introduced by the tax reform, it becomes fundamental to understand how these new mechanisms will impact the competitiveness and sustainability of the hub. The preservation of the ZFM’s competitive differential cannot be evaluated solely under a symbolic prism, but must be measured in terms of the real capacity to sustain the sectors responsible for the PIM’s economic core. Thus, this study seeks to examine the impacts of the tax reform on the electro-electronic sector installed in the ZFM, identifying the changes in the favored regime, the sector’s recent position in SUFRAMA’s indicators, and the main regulatory and strategic challenges arising from the new legal-tax framework.

2. Material and Methods

The present study adopted a methodological approach that combined qualitative and quantitative elements, with the purpose of generating practical subsidies on the effects of tax reform. The research was characterized as descriptive-analytical, seeking to examine the impacts of tax reform on the electro-electronic sector installed in the Manaus Free Trade Zone (ZFM). This methodological design aimed to identify the changes in the favored regime, the recent position of the sector in SUFRAMA’s indicators, and the main regulatory and strategic challenges arising from the new legal-tax framework.

To this end, a research strategy was employed that integrated a literature review, documentary analysis, and examination of public data. The central focus was on the relationship between tax reform and the recent performance of the electro-electronic sector, which operates in the Manaus Industrial Pole (PIM). The documentary analysis covered a set of legal norms and official documents, essential for understanding the legal framework.

Decree-Law No. 288/1967 (Brazil, 1967), Article 40 of the Transitional Constitutional Provisions Act (ADCT) of the 1988 Federal Constitution (Brazil, 1988), and Constitutional Amendment No. 83/2014 (Brazil, 2014) were examined. Constitutional Amendment No. 132/2023 (Brazil, 2023), Complementary Law No. 214/2025 (Brazil, 2025), and Technical Note No. 6/2025/COGEA/SAE/SUFRAMA (SUFRAMA, 2025) were included. Additionally, Complementary Law No. 227/2026 (Brazil, 2026), the Regulation of the Social Contribution on Goods and Services (RCBS) (Brazil, 2026), and the Regulation of the Tax on Goods and Services (RIBS) (IBS Management Committee, 2026a) were analyzed, in addition to Resolution CGIBS No. 14/2026 (IBS Management Committee, 2026b) and Law No. 2,826/2003 (Amazonas, 2003).

This stage of documentary analysis allowed for the identification of the legal architecture of the new tax regime, as well as the mechanisms of suspension, zero rate, conditional exemption, and presumed credits applicable to the incentivized area. Before the reform, the main federal tax incentives included exemption from the Tax on Industrialized Products (IPI), reduction of Import Tax (II) on inputs, a 75% reduction in Corporate Income Tax (IRPJ) for companies included in programs by the Superintendence of the Development of the Amazon (SUDAM), and the suspension of PIS and COFINS contributions on product outputs to the ZFM, in addition to state ICMS exemption or presumed credit.

The tax reform replaced this previous logic with a new methodology, detailed in Complementary Law No. 214/2025. The maintenance of IPI for products with incentivized industrialization in the ZFM whose original rate on December 31, 2023, was equal to or greater than 6.5% was foreseen. For ICMS, a presumptive credit of Tax on Goods and Services (IBS) was established. The PIS/COFINS contributions were replaced by the suspension of IBS and Social Contribution on Goods and Services (CBS) on imports and a zero rate on national operations destined for the ZFM. The Service Tax (ISS) was integrated into the other IBS rules applicable to the ZFM.

On a quantitative level, public data made available by the Superintendence of the Manaus Free Trade Zone (SUFRAMA) were used. Specifically, the document “Performance Indicators of the PIM 2021-2026” (SUFRAMA, 2026b) was consulted. Data collection focused on total revenue tables for the Manaus Industrial Pole (PIM), revenue by sub-sectors, and the evolution of the workforce by sub-sector. The analysis prioritized annual data for 2025 and partial information for the first two months of 2026, as they represent the most recent period available at the time of the research.

The analysis of the collected data was conducted in light of recent academic literature on the ZFM, with an emphasis on studies addressing the sustainability of the model and the uncertainties following tax reform. The choice of official public data aimed to ensure the traceability and reproducibility of the research, avoiding the use of hypothetical information. For the organization and presentation of the findings, the data were structured into three distinct analytical blocks, according to the nature of the evidence: legal impacts, economic impacts, and prospective impacts.

3. Results and Discussion

The analysis of the research results reveals a complex interaction between the historical incentive structure of the Manaus Free Trade Zone (ZFM), the recent dynamics of the electro-electronic sector, and the profound changes introduced by the tax reform. Initially, the ZFM was established by Decree-Law No. 288/1967 with the objective of promoting the economic development of Western Amazonia, compensating for the region’s geographical isolation. This tripartite model, encompassing the Industrial, Commercial, and Agricultural zones, reflects a conception of regional development that transcends the mere creation of an industrial hub, seeking broader productive integration.

The tax incentives granted to the industries of the ZFM have always been crucial for their competitiveness. Among the main ones, the exemption from the Tax on Industrialized Products (IPI) for products manufactured in the hub and sold in the national market, the reduction of the Import Tax (II) on raw materials and capital goods, the 75% reduction of the Corporate Income Tax (IRPJ) for companies included in SUDAM programs, the exemption or reduction of the Tax on Circulation of Goods and Services (ICMS) granted by the State of Amazonas, and the suspension of contributions to PIS and COFINS on the exit of products destined for the ZFM stand out. These benefits, synthesized in the original legislation, aim to equalize production and logistics costs, making the region attractive for industrial investments.

The enjoyment of these incentives is conditioned on compliance with the Basic Production Processes (PPBs), which are minimum sets of mandatory industrial operations. The PPBs ensure that tax benefits result in effective value aggregation in the region, avoiding simple commercial triangulation and promoting local industrial development. SUFRAMA and the Ministry of Development, Industry, Trade, and Services are the bodies responsible for monitoring compliance with these requirements, ensuring the integrity of the model.

Academic literature corroborates the importance of the ZFM, pointing out that its effects go beyond the economic dimension. Ribeiro, Marinho and Carvalho (2024) highlight that the model contributes to environmental preservation by sustaining urban and formal economic activities in the Amazon, and to the containment of predatory pressures on the forest. The ZFM, therefore, plays a relevant geopolitical role in the deconcentration of investments and income generation, in addition to being a factor of socioeconomic stability in the region.

Within the Manaus Industrial Pole (PIM), the electro-electronic sector holds a prominent position. This complex encompasses the manufacturing of televisions, air conditioners, mobile phones, smartphones, audio and video equipment, electronic components, and IT goods. It is a segment of high technological intensity and particularly sensitive to tax and logistical costs, making it a barometer of the pole’s competitiveness.

SUFRAMA’s data for 2025 confirm the sector’s relevance. The PIM’s total revenue reached R$ 229 billion. Of this amount, the electro-electronic subsector, excluding IT goods, generated R$ 38.6 billion, while IT goods registered R$ 47.9 billion. Together, the electro-electronic complex totaled R$ 86.5 billion, which corresponded to approximately 37.81% of the PIM’s total revenue. This significant share underscores the importance of any change in the sector’s competitiveness for the regional economy.

The magnitude of revenue and the concentration of labor in the electro-electronic sector highlight that the discussion about the impacts of tax reform is crucial. In 2025, the electro-electronic complex, including IT goods, concentrated 47,630 jobs, representing 36.12% of the average workforce in the PIM, which totaled 131,867 workers. These numbers demonstrate that the preservation of the ZFM’s competitive differential cannot be merely symbolic, but must be measured by the real capacity to sustain the sectors that form the economic core of the hub.

The tax reform, instituted by Constitutional Amendment No. 132/23, represented the most profound restructuring of the Brazilian tax system since 1988. It proposed the replacement of five consumption taxes (IPI, ICMS, ISS, PIS, and COFINS) with a simplified system, based on the Tax on Goods and Services (IBS), with state and municipal competence, the Social Contribution on Goods and Services (CBS), with federal competence, and the Selective Tax (IS). The transition to the new system is scheduled to occur gradually between 2026 and 2033.

For the ZFM, EC No. 132/23 introduced Article 92-B to the Act of Transitional Constitutional Provisions (ADCT), which determined the preservation of the competitiveness level already granted to the ZFM by the legislation of the extinguished taxes (Brazil, 2023). This constitutional provision is fundamental, as it shifts the analysis from mere rhetoric to the requirement of practical compatibility between the new taxes and the constitutional guarantee of the model. Complementary Law No. 214/25 and Technical Note No. 6/2025 from SUFRAMA confirmed the non-extinction of the differentiated treatment for the ZFM.

The tax reform, therefore, did not eliminate the favored treatment of the ZFM, but rather rebuilt it through a new methodology. This methodology is based on mechanisms such as suspension, conditional exemption, zero rate, and presumed credits of IBS and CBS, in addition to the selective preservation of IPI in specific hypotheses. LC No. 214/25, for example, suspended the requirement for IBS and CBS on the import of inputs by incentivized industries for use in the ZFM (art. 443), converting it into an exemption in defined situations. It also set the rates of these taxes to zero on shipments of nationally produced manufactured goods to entities qualified in the ZFM (art. 445).

Additionally, LC No. 214/25 established presumed credits for the acquisition of national goods, intermediate goods, and goods produced by the incentivized industry itself (Arts. 447, 449, and 450). Article 454 of the same complementary law established the reduction to zero of IPI rates, as of January 1, 2027, for products whose IPI Tax Incidence Table (TIPI) rate on December 31, 2023, was less than 6.5%. For other products with incentivized industrialization in the ZFM, positive IPI rates were maintained, preserving the competitive differential in relation to competitors outside the incentivized area (Brazil, 2025).

These normative devices, although they preserve the favored treatment, introduce greater operational complexity. The ZFM’s competitive advantage came to depend less on the simple formal permanence of incentives and more on the efficiency of control mechanisms, the timeliness of crediting, regulatory clarity, and coordination between the Union, the IBS Management Committee, tax administrations, and SUFRAMA. The literature, as pointed out by Oliveira and Jesus (2025), converges in highlighting that the legal preservation of the regime does not, in itself, eliminate the risks to regulatory security and competitive neutrality.

The 2026 regulatory layer, composed of LC No. 227/26, the CBS Regulation (RCBS), and the IBS Regulation (RIBS), filled the gaps left by LC No. 214/25, detailing the conditions for enjoying the benefits. LC No. 227/26 established the IBS Management Committee (CGIBS), a technical and operational entity, whose performance is indirectly relevant to the ZFM, as the effectiveness of competitiveness preservation mechanisms depends on qualification, proof of warehousing, and segregated calculation. The absence of clear regulation on the verification of the Basic Production Process, due to a veto, leaves the division of responsibilities between SUFRAMA and the tax administrations open.

The RCBS and RIBS dedicate specific chapters to the ZFM, detailing the suspension mechanisms, zero rate, and presumed credits. The suspension of incidence on the import of material goods by incentivized industry, with conversion into exemption, is provided for in articles 514 of the RIBS and 528 of the RCBS. The zero rate on shipments of nationally industrialized goods to entities qualified in the ZFM is addressed in articles 516 of the RIBS and 529 of the RCBS, conditioned on the indication of registration with SUFRAMA and proof of entry into the area. The zero rate on operations between incentivized industries with intermediate goods is in articles 519 of the RIBS and 530 of the RCBS.

The most relevant normative finding for the electro-electronic sector lies in the asymmetry of the design of presumed credits between the two regulations. The RIBS establishes three distinct presumed credits: 7.5% or 13.5% on the acquisition of unburdened national manufactured goods (art. 518); 7.5% on the acquisition of intermediate goods produced in the ZFM (art. 520); and percentages from 55% to 100% on the outstanding balance of IBS calculated in the period, varying according to the type of good (art. 521). The RCBS, in turn, provides a single presumed credit for the incentivized industry, calculated on the value of the operation, at a rate of 6% for products subject to art. 454 of LC nº 214/25 and 2% in other cases (art. 531).

This asymmetry is twofold. Firstly, the presumed acquisition credits provided for in articles 518 and 520 of the RIBS have no correspondence in the CBS, which means that the exemption of entries in the incentivized area generates credit replenishment only at the state and municipal tax level. Secondly, the calculation bases differ: the presumed IBS credit is levied on the debit balance of the tax period, while that of the CBS is levied on the transaction value. This difference is structurally significant, as the IBS design is self-compensating, maintaining the proportion of the debit neutralized by the incentive, whereas in the CBS design, the presumed credit is a fixed percentage of the transaction value, and the fraction of the CBS debit neutralized by the incentive decreases as the reference rate increases. This vulnerability, an interpretive construction by the author, arises from the regulatory choice and not from the complementary law.

An additional point that directly affects the electro-electronic sector, with its dependence on imported inputs, is the suspension of import incidence, converted into exemption with industrial use (RIBS art. 514 and RCBS art. 528). Although it eliminates the tax upon entry, this measure also eliminates the corresponding credit. The effect is neutral on the input cost, but relevant for calculation, as it produces higher debit balances upon exit. The asymmetry of bases between the IBS and CBS regulations becomes crucial here: in IBS, the presumed credit falls on the debit balance, self-compensating the effect, but in CBS, the presumed credit is a fixed percentage of the transaction value, which can lead to a reduction in the fraction of the debt neutralized by the incentive as the rate rises.

The preservation of the ZFM regime also became the subject of litigation. In May 2026, the Federation of Industries of the State of São Paulo (FIESP, 2026) filed a public civil action against the Union and the CGIBS, questioning the percentages of presumed IBS and CBS credits for the incentivized industry. FIESP argues that these percentages would exceed the preservation determined by article 92-B of the ADCT and would create a new benefit. The electro-electronic sector is central to this controversy, and the judicial pending demonstrates that legal certainty, although formally guaranteed, still faces challenges in the regulatory stage.

The most debated impact of the tax reform on the electro-electronic sector of the ZFM is the “IPI paradox”, as identified by tax doctrine (Andrade, 2024). Historically, the IPI exemption granted to ZFM industries created a significant price differential, making production in Manaus economically viable, even with logistical costs. However, with the gradual replacement of IPI by IBS and CBS for national manufacturers, this competitive differential tends to decrease, which represents a risk of erosion of the competitive advantage.

Law No. 214/25, in its Article 454, sought to address this issue by establishing differentiated criteria for the maintenance of IPI. Products with a rate lower than 6.5% in the TIPI of December 31, 2023, will have their rates reduced to zero starting in 2027, while for other products, the IPI will be maintained as an instrument for preserving regional advantage. This hybrid solution has generated debates among tax lawyers about the real extent of the protection (Andrade, 2024; Ávila, 2024), indicating the complexity of the transition.

The analysis of impacts by segment within the electro-electronic sector reveals heterogeneity. For televisions and air conditioners, where the PIM has a strong presence, maintaining the IPI on products manufactured outside the ZFM is essential to preserve the competitive differential. For cell phones and IT goods, segments that have grown in the PIM, the effectiveness of the new compensatory mechanisms is crucial for the hub to continue attracting high-technology investments. The practical implementation of presumed IBS and CBS credits, however, presents challenges such as the difficulty in quantifying the competitive differential, possible legal challenges regarding constitutionality, and uncertainty about the calculation during the transition (Ávila, 2024).

In terms of economic impacts, the recent dynamics of revenue and sectoral employment, analyzed from SUFRAMA data for the first two months of 2025 and 2026, show heterogeneous behavior. While the total revenue of PIM presented a slight retraction of 0.38%, going from R$ 37.37 billion in 2025 to R$ 37.23 billion in 2026, the electro-electronic sector, excluding IT goods, grew 5.26%, from R$ 5.63 billion to R$ 5.92 billion in the same period.

In contrast, the computer goods subsector of the electro-electronic hub registered a decline of 14.09%, with revenue falling from R$ 8.16 billion in 2025 to R$ 7.01 billion in 2026. In aggregate, the total electro-electronic complex showed a drop of 6.19%, going from R$ 13.79 billion to R$ 12.94 billion. This recent fluctuation, although it cannot be immediately attributed to the tax reform due to the transition period and the 2026 test rates, suggests that technology and logistics-intensive segments, such as computer goods, remain sensitive to cost uncertainties, credit replenishment, and regulatory predictability.

Regarding employment, SUFRAMA data for 2025 indicate that the electro-electronic sector, including IT goods, concentrated 47,630 jobs, representing 36.12% of the total average workforce in the PIM. This sectoral employment relevance reinforces that fiscal competitiveness in the ZFM is not just a business advantage, but a factor of social and regional stability. The weakening of the electro-electronic complex could have significant repercussions on production, labor income, indirect revenue collection, and the model’s capacity to sustain economic alternatives to predatory pressure on the Amazonian territory.

The documentary and quantitative results allow us to state that the tax reform generated a dual scenario for the ZFM. On the one hand, there was the normative preservation of competitiveness through the mechanisms expressed in Complementary Law No. 214/25. On the other hand, significant challenges remain for these instruments to translate, in practice, into an effect equivalent to previous incentives. The first challenge is operational legal certainty, which depends on clarity regarding eligibility, proof of goods entry, credit reversal, and refund deadlines. The productive dynamics of the electro-electronic sector, intensive in input flow, are particularly vulnerable to regulatory delays.

The second challenge is intra-sectoral heterogeneity, evidenced by distinct behavior between strictly defined electro-electronics and IT goods. This indicates that the reform’s impact will not be homogeneous, requiring monitoring and specific strategies per sub-sector, considering the composition of value chains, the origin of inputs, and the commercialization regime. The third challenge is the need for federal and institutional coordination. The model’s permanence will depend on integrated governance between taxation, regional development, and industrial policy, as pointed out by Technical Note nº 6/2025 from SUFRAMA (SUFRAMA, 2025).

The fourth challenge is the strategic adaptation of companies. In an environment of tax transition, companies in the electro-electronic sector need to strengthen their tax governance, documentary compliance, logistical planning, supply chain review, and permanent assessment of credit appropriation. The reform did not eliminate the advantage of the ZFM, but it made the entrepreneurial capacity to correctly capture benefits and avoid losses due to procedural non-compliance more relevant. The institutional agenda, therefore, must be proactive, seeking swift and precise regulation of the mechanisms of LC nº 214/25, strengthening the technical role of SUFRAMA, and using the reform as an opportunity to increase the technological density of the hub, encouraging innovation and local value aggregation.

In summary, the tax reform preserved the legal basis of the competitive advantage of the Manaus Free Trade Zone, especially for the electro-electronic sector, through new suspension mechanisms, zero rate, and presumed credits of IBS and CBS, in addition to the selective maintenance of IPI. However, the stability of the model was transferred to the regulatory and operational stage, introducing significant challenges related to legal certainty, heterogeneity of intra-sectoral impacts, and the need for institutional coordination and strategic adaptation of companies. The future effectiveness of the model will depend on regulatory clarity, control efficiency, and the capacity to sustain the key sectors of the PIM, such as the electro-electronic sector, which has demonstrated its economic and social centrality.

4. Conclusion

The study examined the impacts of the tax reform on the electro-electronic sector installed in the Manaus Free Trade Zone, identifying the changes in the favored regime, the sector’s position in SUFRAMA’s indicators, and the regulatory and strategic challenges arising from the new legal-tax framework. It was found that the reform did not eliminate the favored treatment of the ZFM, but rather reconstructed it through mechanisms such as suspension, conditional exemption, zero rate, and presumed credits of IBS and CBS, in addition to the selective preservation of IPI in cases defined by law. It was observed that the electro-electronic complex, including IT goods, maintained its central position in the Manaus Industrial Pole, invoicing R$ 86.5 billion in 2025, which corresponded to almost 38% of the PIM’s total revenue, and concentrating 47,630 jobs. A relevant asymmetry was identified in the design of presumed credits between the IBS and CBS regulations, with distinct calculation bases that may generate vulnerabilities in the CBS tax relief as reference rates rise. The analysis of the “IPI paradox” revealed that the selective maintenance of this tax is crucial to preserve the competitive differential in certain segments, while the effectiveness of the new compensatory mechanisms is essential for others. The study’s main contribution lies in demonstrating that the reform transferred the stability of the ZFM model to the regulatory and operational stage, requiring a new, more complex legal architecture dependent on clarity and efficiency.

However, the results should be interpreted in light of limitations, such as the aggregated nature of economic data, which prevented the distinction of performance by company or product, and the impossibility of establishing direct causality of economic impacts, given the transition period and the 2026 test rates. The instability of the regulatory framework, still under regulation and subject to litigation, also represents a factor of uncertainty. To maintain the competitiveness of the electro-electronic sector, swift and precise regulation of the mechanisms of Complementary Law No. 214/25 is suggested, strengthening the technical role of SUFRAMA, and using the reform as an opportunity to increase the technological density of the hub, encouraging innovation and local value aggregation. The defense of the ZFM model, therefore, transcends the fiscal dimension, articulating with regional sustainability and environmental preservation, which requires institutional coordination and strategic adaptation of companies to ensure the effectiveness of benefits and the long-term sustainability of the PIM.

Bibliographic References

Brasil. 1967. Decreto-Lei n. 288, de 28 de fevereiro de 1967. Altera as disposições da Lei n. 3.173, de 6 de junho de 1957, e regula a Zona Franca de Manaus. Diário Oficial da União, Brasília, 28 fev. 1967. Disponível em: https://www.planalto.gov.br/ccivil_03/decreto-lei/del0288.htm. Acesso em: 12 abr. 2026.

Brasil. 2014. Emenda Constitucional n. 83, de 5 de agosto de 2014. Altera o art. 40 do Ato das Disposições Constitucionais Transitórias para prorrogar as disposições relativas à Zona Franca de Manaus. Diário Oficial da União, Brasília, 6 ago. 2014. Disponível em: https://www.planalto.gov.br/ccivil_03/constituicao/emendas/emc/emc83.htm. Acesso em: 12 abr. 2026.

SUFRAMA Superintendence of the Manaus Free Trade Zone. 2026b. Performance Indicators of the Manaus Industrial Pole 2021-2026. Notebook

Article originating from the Final Course Work of the Specialization in Tax Management of the MBA USP/Esalq

To learn more about the course, click here and access the MBX Academy platform