Article

Tax Management

October 13, 2026

Tax reform in Brazil and its effects on wholesale trade: empirical analysis of economic and fiscal impacts

Tax Reform in Brazil and Its Effects on Wholesale Trade: Empirical Analysis of Economic and Fiscal Impacts

Milton de Castro Andrioni; Raissa Alvares de Matos Miranda

DOI: 10.22167/2675-6528-202603287

Article derived from a Course Conclusion 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 Instituto Pecege for textual synthesis and organization.

Summary

The Brazilian Tax Reform represents a structural change in consumption taxation, with potential impacts on economic efficiency and business competitiveness. The study aimed to empirically analyze the effects of the transition from a cumulative system to a Value Added Tax (VAT) based model in the wholesale sector. A quantitative and comparative approach was adopted, based on data from three representative companies (Assaí Atacadista S.A., Arezzo Indústria e Comércio S.A., and Grupo Mateus S.A.) in the period from 2021 to 2025. The results indicated high cumulativeness in the previous regime, with an average Estimated Cumulativeness Index (ICE) between 0.69 and 0.77, suggesting that up to 77% of the tax burden was unrecoverable. The effective sales tax rate, which reached approximately 20.7% in companies with low value added, was reduced to about 6% to 8% in the post-reform scenario, with a reduction of up to 70% in the effective tax burden and elimination of the cascading effect. It was concluded that the reform promotes relevant gains in efficiency and economic neutrality, although with varied impacts among companies.

Keywords: wholesale market; tax reform; tax system.

1. Introduction

The Brazilian Tax Reform represents a significant structural change in the national tax collection system, being the result of a long process of debate on the need for modernization. Historically, the country’s tax system has been characterized by high complexity, bureaucracy, and operational costs that compromise business competitiveness (Brazuna, 2023; Hartung, 2020). Historical experience shows that tax reforms produce relevant and immediate economic effects, reconfiguring resource allocation and altering companies’ economic incentives (Neves and Santos, 2024).

The proposed structural transformation, materialized through a constitutional amendment and complementary legislation, seeks to replace the current fragmented model of consumption taxation. The objective is to implement a dual system based on the Tax on Goods and Services (IBS) and the Contribution on Goods and Services (CBS), aiming to simplify collection, reduce economic distortions, and stimulate productive efficiency (Brazuna, 2025; Funchal, 2025). This change transcends the normative sphere, implying a broad reconfiguration of the business environment, with direct impacts on financial management, pricing, and supply chain organization (Múrcia and Pinto, 2025).

In the current tax system, the cumulativeness of consumption taxes, especially in structures like the Programa de Integração Social (PIS) and the Contribuição para o Financiamento da Seguridade Social (COFINS), generates significant distortions. These distortions artificially increase operational costs and encourage suboptimal economic decisions, such as the geographical location of productive activities based on tax benefits, to the detriment of efficiency (Hartung, 2020; Souza, 2020). Furthermore, the high compliance costs and the legal uncertainty associated with the Brazilian tax system constitute significant obstacles to business development, increasing administrative expenses and reducing financial predictability (Brazuna, 2020; de Amorim, 2021).

In this context, the introduction of a Value Added Tax (VAT) based model, operationalized by the IBS and CBS, is an attempt to eliminate cascading incidence through full non-cumulativeness, allowing for the full appropriation of tax credits along the production chain (Brazuna, 2024; Funchal, 2025). However, the effectiveness of this proposal depends on the operational capacity of companies to generate, manage, and offset such credits, which directly impacts the working capital structure, financing needs, and the dynamics of operational costs (Múrcia and Pinto, 2025). Additionally, the incidence of the Selective Tax (IS) on certain products may increase the tax burden of specific sectors, demanding portfolio reviews and adjustments in pricing strategies (Cazati, 2024).

From an accounting and financial perspective, the transition to a non-cumulative system profoundly alters the measurement of economic phenomena in financial statements, modifying the nature of tax assets and liabilities and redefining the logic for calculating the effective tax burden (Brazuna, 2024). The replacement of a fragmented system with a unified model implies relevant changes in the management of tax credits, with direct impacts on liquidity, indebtedness, and operational efficiency indicators (Múrcia and Pinto, 2025). The loss of historical comparability of accounting statements requires the development of new metrics capable of adequately capturing the tax burden and its effects on business profitability (Funchal, 2025), making companies’ adaptability a determining factor of competitiveness (Cazati, 2024; Brazuna, 2025).

Given this context, conducting empirical analyses that go beyond the normative dimension of the reform and investigate the real impacts on companies’ financial performance is structurally relevant. The wholesale sector, characterized by high-volume operations, reduced margins, and high sensitivity to indirect costs, presents itself as a suitable environment for this investigation, as it amplifies the effects of cumulativeness in the previous regime and enhances the benefits of non-cumulativeness in the Value Added Tax model (Hartung, 2020; Funchal, 2025). The present study aims to analyze, comparatively and empirically, the impacts of the Tax Reform on the financial and fiscal indicators of companies in the wholesale sector, already mentioned, using accounting and tax data referring to the five most recent fiscal years, in order to evaluate the effects of the transition to the Value Added Tax (VAT) model.

2. Material and Methods

This research was characterized as a comparative study, with a mixed approach, combining quantitative and qualitative elements. A longitudinal panel analysis was adopted, with the purpose of investigating the effects of the tax structure on economic and financial indicators. This methodological strategy allowed for an integrated analysis, considering both the quantitative dimension of the data and the qualitative interpretation of the results, seeking to identify patterns and heterogeneities among companies, as aligned with the research hypotheses (Andrade, 1999).

The empirical object of the study consisted of data from three publicly traded companies operating in the wholesale sector: Assaí Atacadista S.A. (ASAI3), Arezzo Indústria e Comércio S.A. (ARZZ3), and Grupo Mateus S.A. (GMAT3). The selection of these companies was based on criteria of representativeness, diversity of operational costs, and accessibility of complete and standardized accounting information, following the precepts of intentional sampling in case studies (Gil, 2008).

The data were extracted from the Standardized Financial Statements (DFPs) of the companies, covering the period from 2021 to 2025. This time window allowed for a longitudinal analysis that encompassed both the pre-reform scenario and a post-reform counterfactual simulation. The fundamental variables collected from the Income statement for the year (DRE) included Total Revenue, Cost of Goods Sold (COGS), Gross Profit, Operating Profit (EBIT), and Net Profit, in addition to total operating expenses when available.

For data processing, a standardization process was carried out involving the cleaning of the “Indicator” variable, the transformation of columns into time series, and the structuring of data in panel format, according to the methodology of Iudícibus (1993). This procedure ensured the consistent application of calculations and comparability between the companies and the periods analyzed.

Due to the absence of explicit segregation of sales taxes in the financial statements, the indirect tax burden was estimated using an indirect approach based on the cost structure. For this purpose, a methodology adapted from Siqueira et al. (1999) and Sampaio de Souza (1996) was used. The proxy for the indirect tax burden was the ratio between the Cost of Goods Sold (COGS) and Total Revenue, adjusted by a sectoral calibration coefficient of 0.25, based on macroeconomic evidence of the effective tax burden on consumption in Brazil, according to studies by the Inter-American Development Bank (IDB).

The estimated rate of indirect taxes levied on revenue was subsequently capped at a closed interval of 0.05 to 0.30, in order to mitigate extreme distortions arising from atypical variations in cost structure. After this restriction, the absolute value of taxes was calculated by multiplying Total Revenue by the estimated rate. This approach allowed for the translation of operational cost intensity into a plausible proxy for the effective tax burden.

To incorporate the dimension of tax cumulativeness, a central phenomenon in the pre-reform system, the Estimated Cumulativeness Index (ICE) was developed. This indicator was based on proxy tax credits endogenously modeled, derived from the company’s own operational structure. The credits were modeled as a function of the Cost of Goods Sold (COGS) adjusted by the gross margin, approximating the model to the non-cumulativeness principle of the Value Added Tax (VAT), as demonstrated by Varsano et al. (2001).

The ICE was calculated by subtracting the amount of estimated credits from the amount of estimated taxes, and dividing the result by the amount of taxes itself. A restriction was applied to the interval [0,1], truncating negative values to zero (absence of net cumulativeness) and values greater than one to one (total cumulativeness). This construction allowed operationalizing the hypothesis that companies with lower operating margins exhibit a higher degree of tax cumulativeness.

The post-reform scenario simulation was carried out based on two projected rates for the dual VAT (IBS + CBS): a base rate of 26.5% and a pessimistic rate of 28%. These rates were defined based on ranges discussed in specialized literature and in ongoing legislative proposals. Taxes were recalculated for the post-reform scenario and adjusted by the ICE, reflecting the premise of eliminating cumulativeness in the new model, with full recovery of tax credits.

From the estimated variables, several indicators of tax and operational efficiency were constructed, organized into three analytical dimensions. These included the Effective Tax Rate on Sales (AETV), the Tax Cost per Monetary Unit of Operational Profit (CTLOP), the Estimated Cumulativeness Index (ICE), the Net Margin Adjusted by Taxation (MLAT), the Estimated Tax Impact on COGS (%TribCMV), the Fiscal Autonomy Index (IAF), and the Weight of Tax Expenses on Operational Expenses (%DTOp). These indicators allowed for the evaluation of the direct impact of taxation on profitability, efficiency, and cost structure, contributing to the testing of hypotheses.

The dynamic analysis was complemented by the calculation of tax elasticity, defined as the percentage variation in tax expenditure for each 1% variation in revenue, according to the methodology of Siqueira et al. (1999). This metric allowed for the evaluation of the sensitivity of the tax burden to economic growth and the identification of progressivity or proportionality in the tax system. All calculations were implemented in a Python environment, using the pandas and numpy libraries, with a vectorized, reproducible, and scalable structure (Gil, 2008; Andrade, 1999).

Complementarily, a qualitative analysis was performed based on management reports, explanatory notes to the financial statements, and institutional documents provided by companies and regulatory bodies, such as the Securities and Exchange Commission (CVM) and B3 S.A. – Brasil, Bolsa, Balcão (B3). The material was subjected to a thematic content analysis, with a priori categories aligned with the study’s objectives, as per Creswell (2010) guidelines.

The predefined thematic categories for qualitative analysis were: “Perceived Challenges in Transition”, “Identified Opportunities”, “Adaptation Strategies”, “Described Operational Impacts”, and “Competitiveness Concerns”. The frequency of citations per category and company was quantified, and the most significant excerpts were discursively analyzed to capture managers’ nuances, fears, and expectations regarding the tax reform.

3. Results and Discussion

The empirical analysis of the impacts of the tax reform in the wholesale sector revealed distinct patterns among the selected companies, evidencing operational and fiscal particularities. Initially, the investigation focused on Assaí Atacadista S.A. (ASAI), representative of the high-volume, low-margin wholesale-retail model. Subsequently, Arezzo Indústria e Comércio S.A. (ARZZ) was examined, standing out for its operation in the wholesale channel (B2B) with higher added value. Finally, Grupo Mateus S.A. (GMAT) was analyzed, characterized by a hybrid model and strong regional presence, which contributed to the heterogeneity of the sample and the robustness of the findings.

Revenue, growth, and projection data for the period 2021-2025, according to the survey results, indicated consistent revenue expansion for ASAI, which grew from R$41,898 million in 2021 to R$77,307 million in 2025. However, this growth was accompanied by a significant drop in net profit, which fell from R$1,610 million to R$497 million in the same period. This behavior suggests margin compression or an increase in operational and tax costs, as ASAI’s Earnings Before Interest and Taxes (EBIT) grew from R$2,520 million to R$4,114 million, but this did not proportionally translate into net profit.

In contrast, Arezzo (ARZZ) demonstrated even more accelerated revenue growth, increasing from 2,924 million reais in 2021 to 11,819 million reais in 2025. This increase was accompanied by a significant improvement in net profit, which rose from 345 million reais to 911 million reais, indicating greater efficiency in converting revenue into results. Grupo Mateus (GMAT) also presented robust revenue growth, from 15,877 million reais to 38,424 million reais, with a consistent increase in net profit, from 769 million reais to 1,833 million reais. These results suggest a better balance between expansion and profitability, corroborating the industrial economics literature on margins in competitive markets (Varian, 2014).

The analysis of the Cost of Goods Sold (COGS) reinforced the structural heterogeneity among companies. ASAI and GMAT presented high COGS, proportional to revenue, with ASAI ranging from 34,753 million reais in 2021 to 64,154 million reais in 2025, maintaining a ratio close to 83% of revenue. GMAT exhibited a similar pattern, with COGS evolving from 12,174 million reais to 29,817 million reais, representing approximately 77% to 78% of revenue. In contrast, ARZZ presented a proportionally lower COGS, ranging from 1,379 million reais to 5,324 million reais, with a ratio close to 45% to 50% of revenue, indicating greater value added in its operations. This structural difference is fundamental to understanding the tax incidence, as cumulative systems tend to penalize production chains with a higher weight of operational costs, amplifying distortions (Besanko et al., 2013).

The estimated tax rate, calculated according to the study’s methodology, clearly showed the differentiation of the tax burden between companies under the previous tax system. ASAI maintained stable rates around 20.7% to 20.9% between 2021 and 2025, reflecting its high COGS/Revenue ratio. GMAT showed similar behavior, with rates between 19.1% and 19.7%. In contrast, ARZZ registered significantly lower rates, ranging between 11.2% and 11.7%. This difference indicates that the estimated indirect tax burden for ASAI and GMAT was approximately 80% higher than that of ARZZ, in relative terms. The results reinforce the hypothesis of non-neutrality of the indirect tax system, which tends to generate distortions proportional to the firms’ productive structure (Musgrave and Musgrave, 1989).

The inclusion of tax credits in the analysis allowed for the observation of relevant differences in companies’ efficiency in recovering taxes along the production chain. ASAI showed a growth in credits from 2,034 million reais in 2021 to 3,753 million reais in 2025, while GMAT evolved from 751 million reais to 1,825 million reais, and ARZZ from 105 million reais to 412 million reais. In relative terms, ARZZ demonstrated a higher proportion of credits in relation to CMV, reflecting its greater operational margin and tax recovery capacity. ASAI and GMAT, despite presenting higher absolute credit values, had lower relative efficiency, given the high volume of costs. This behavior is consistent with the adopted modeling, in which credits depend on the operational margin, and reinforces the idea that more economically efficient companies can reduce the net impact of taxation, a central principle in VAT theory (Bird and Gendron, 2007).

The indirect tax structure proved to be strongly conditioned by the companies’ operational structure. ASAI, with growing revenue and high taxes, showed a deterioration in profit, evidencing strong cost pressure. GMAT, although also with a high tax burden, managed to expand its profit, indicating a better operational balance. ARZZ, with a lower relative burden, exhibited significant profit growth, demonstrating greater structural efficiency. These results confirm hypotheses H1 and H2, which postulate that the tax burden is not neutral and penalizes companies with higher cost intensity, and that companies with lower operating margins exhibit a higher degree of tax cumulativity. The analysis of taxation, therefore, must simultaneously consider revenue, costs, and margin, as the mere observation of absolute values is not sufficient to capture the complexity of the phenomenon (Rezende, 2010).

The Estimated Cumulativeness Index (ICE) revealed significant differences in the degree of tax cumulativeness among companies. ASAI registered an ICE ranging between 76.59% and 76.75% throughout the analyzed period, while GMAT presented values close to 76%, both demonstrating a high level of cumulativeness. In contrast, ARZZ exhibited a lower average ICE, around 69%, indicating less exposure to the effects of cumulative taxation. Although the ICE is an indicator developed in this research, its results are consistent with studies that point to the existence of economic distortions associated with the limited recovery of tax credits in the Brazilian system.

The literature on indirect taxation, as highlighted by Ebrill et al. (2001), emphasizes that broad credit mechanisms are essential for the economic neutrality of consumption taxes. Keen (2013) demonstrates that cumulative input taxation tends to generate economic inefficiencies and allocative distortions. In this context, the high levels of ICE observed in ASAI and GMAT suggest a greater potential benefit from the implementation of the Goods and Services Tax (IBS) and the Contribution on Goods and Services (CBS), as these companies operate with structures more intensive in costs and goods subject to cumulative effects. On the other hand, ARZZ, which already showed lower relative cumulativeness, tends to experience less significant gains in terms of reducing the indirect tax burden. These results corroborate the literature by indicating that the effects of the Tax Reform will not be uniform across economic sectors, depending on the operational structure, the supply chain, and the intensity of cumulativeness currently incorporated into business costs (Atkinson and Stiglitz, 1980).

The joint analysis of the Effective Tax Rate on Sales (AETV_real) and the Tax Cost per Unit of Operational Profit (CTLOP_real) allowed for the measurement of the intensity of the indirect tax burden on the generation of operational value. ASAI presented a practically constant AETV_real, varying from 0.21 in 2021 to 0.21 in 2025, indicating that approximately 20.7% of revenue was absorbed by indirect taxes. This high level translated into an extremely high CTLOP_real, reaching 3.45 in 2021, 3.93 in 2022, 4.37 in 2023, 4.05 in 2024, and 3.89 in 2025, meaning that the company paid between 3.4 and 4.3 monetary units in taxes for each unit of operational profit generated.

GMAT exhibited similar behavior, with AETV_real ranging between 0.19 and 0.19, and CTLOP_real between 2.99 and 3.32, evidencing strong tax burden. In contrast, ARZZ showed significantly lower AETV_real, between 0.11 and 0.12, and CTLOP_real ranging between 1.02 and 1.78, indicating lower sensitivity of operating profit to taxation. These data demonstrate that the previous tax system imposed relatively higher costs on low-margin companies, reducing their value generation capacity. Public economics literature emphasizes that tax cumulativeness increases the marginal cost of companies and reduces productive efficiency (Pindyck and Rubinfeld, 2009). The empirical results confirm this theoretical prediction, by evidencing that companies such as ASAI and GMAT faced greater deterioration in the ratio between taxes and operating profit, reinforcing hypothesis H1.

The analysis of the indicators Adjusted Net Margin (MLAT_real), Estimated Tax Impact on COGS (TribCMV_real), Fiscal Autonomy Index (IAF_real), and Weight of Tax Expense on Operational Expenses (DTOp_real) revealed the structural effects of indirect taxation on the profitability and cost composition of companies. ASAI’s MLAT_real showed a downward trend, decreasing from 0.24 in 2021 to 0.21 in 2025, reflecting a compression of profitability adjusted for taxation. GMAT maintained a relatively stable MLAT_real, varying between 0.23 and 0.24, while ARZZ showed a more pronounced decrease, from 0.23 to 0.18, indicating a relevant impact of operational expansion on profitability. TribCMV_real showed that between 17% and 19% of COGS corresponded to non-recoverable taxes, with ASAI ranging from 0.19 to 0.19, GMAT from 0.18 to 0.18, and ARZZ from 0.17 to 0.17. The IAF_real revealed striking differences: ARZZ presented high values, between 4.47 and 4.87, indicating a greater capacity to absorb the tax burden, while ASAI presented values between 0.77 and 0.82, and GMAT between 1.07 and 1.21, evidencing greater vulnerability. The DTOp_real reinforced this analysis, with ASAI ranging from 1.77 to 1.87, GMAT from 1.09 to 1.32, and ARZZ from 0.24 to 0.28. The results indicate that indirect taxation affects not only the bottom line but the entire cost and profitability structure, corroborating the theory that cumulative taxes distort production decisions (Stiglitz, 2000).

The introduction of the Value Added Tax (VAT) based counterfactual scenario revealed profound structural transformations in the analyzed indicators. The Effective Sales Tax Rate (AETV_ref) showed a significant reduction in all companies, with ASAI going from approximately 0.20 to values between 0.06 and 0.06, GMAT from approximately 0.19 to values between 0.06 and 0.06, and ARZZ from approximately 0.11 to values between 0.08 and 0.08. This reduction represents a drop of approximately 70% in the effective sales tax burden. The Tax Cost per Monetary Unit of Operating Profit (CTLOP_ref) also showed an expressive reduction, with ASAI falling from values between 3.4–4.3 to 1.03–1.28, GMAT from 3.0–3.3 to 0.99–1.13, and ARZZ from 1.0–1.78 to 0.71–1.24. The simultaneous reduction of the AETV and CTLOP indicates that VAT not only reduces the effective tax burden but also improves the efficiency in converting revenue into operating profit, confirming hypothesis H3 and being consistent with the value-added tax theory, which establishes non-cumulativeness as a fundamental principle to ensure economic neutrality (Bird and Gendron, 2007).

The Estimated Tax Impact on COGS indicator (TribCMV_ref) showed a value equal to zero for all companies and periods analyzed in the post-reform scenario. This result stems directly from the logic of VAT, in which taxes levied throughout the supply chain are recoverable through the credit system. In the previous regime, TribCMV_real varied between approximately 17% and 19% of COGS, evidencing the presence of taxation incorporated into costs. The elimination of this component in the post-reform scenario confirms the neutrality of VAT and the suppression of the cascading effect, a characteristic widely recognized in the literature (Ebrill et al., 2001). Consequently, costs now predominantly reflect economic and operational factors, reducing distortions in price formation and investment decisions (Keen, 2013).

The Fiscal Autonomy Index (IAF_ref) showed significant improvement for all companies in the post-reform scenario. ASAI registered values between 2.64 and 2.74, GMAT between 3.29 and 3.57, and ARZZ between 6.52 and 6.69, all higher than those observed in the previous scenario. These results indicate a greater capacity for value generation in relation to the tax burden and suggest a strengthening of the companies’ financial position, especially for ASAI and GMAT, which were more impacted by cumulativeness. The indicator Tax Burden on Operating Expenses (DTOp_ref) also showed a significant reduction in the participation of taxes in operating expenses. Compared to the current scenario, all companies presented a relevant decrease in the tax burden on their expenses, freeing up resources for productive activities and investments. This behavior is compatible with economic theory, according to which the reduction of tax distortions improves allocative efficiency (Harberger, 1962).

Even in the pessimistic scenario, considering a rate of 28%, the indicators remained substantially more favorable than those observed in the previous regime. The AETV_ref_pess and CTLOP_ref_pess continued to be significantly lower than historical levels, demonstrating that the gains from the elimination of cascading taxation remain relevant even under higher rates. This result reinforces the argument that the efficiency of VAT is primarily associated with the non-cascading nature and the breadth of its taxable base, and not solely with the level of the nominal rate (Bird and Gendron, 2007). The analysis of the elasticity of the tax burden in relation to revenue revealed values close to 1 for the three companies in the previous system, indicating that tax growth proportionally followed the expansion of economic activity, without gains in tax efficiency. ASAI presented an elasticity of 1.03 in 2022 and 1.01 in 2023, followed by a reduction to 0.95 in 2024 and 0.91 in 2025. GMAT registered 1.09 in 2022 and 1.02 in 2023, moving to 0.93 in 2024 and 0.97 in 2025. ARZZ showed greater fluctuation, with values of 0.92 in 2022, 0.95 in 2023, 1.05 in 2024, and 0.88 in 2025. Overall, the results show that the estimated taxes generally followed the variation in revenue, although there were annual differences between the companies. The adoption of VAT reduces cascading taxation, improves economic efficiency, and strengthens the financial position of the analyzed companies, corroborating hypotheses H3, H4, and H5.

In summary, the research results confirmed the high cumulativeness in the previous tax system, with the Estimated Cumulativeness Index (ICE) averaging between 0.69 and 0.77, indicating that a significant portion of the tax burden was unrecoverable. The effective sales tax rate, which reached approximately 20.7% in low value-added companies, was projected for a substantial reduction to about 6% to 8% in the post-reform scenario, representing a decrease of up to 70% in the effective tax burden and the elimination of the cascading effect. These findings demonstrate that the tax reform promotes relevant gains in efficiency and economic neutrality, although with varied impacts among companies in the wholesale sector, depending on their operational and cost structures.

4. Conclusion

This research analyzed the impacts of the transition from a cumulative tax system to a Value Added Tax (VAT) based model on wholesale companies. It was found that the previous tax system exhibited high cumulativeness, with an average Estimated Cumulativeness Index (ICE) between 0.69 and 0.77, indicating that a significant portion of the tax burden was unrecoverable. It was observed that the effective sales tax rate, which reached approximately 20.7% for low value-added companies, was substantially reduced to about 6% to 8% in the post-reform scenario. This transition resulted in a decrease of up to 70% in the effective tax burden and the elimination of the cascading effect, as demonstrated by the annulment of the Estimated Tax Impact on COGS (TribCMV_ref). The indicators for Tax Cost per Unit of Operating Profit (CTLOP) and Weight of Tax Expense in Operating Expenses (DTOp) also showed significant reductions, while the Fiscal Autonomy Index (IAF) evidenced consistent improvement, even in scenarios with higher tax rates.

The main contribution of this study lies in offering empirical evidence on the microeconomic impacts of the Tax Reform in Brazil, highlighting the relevant gains in efficiency and economic neutrality promoted by the adoption of the VAT. It was found that the effects of the reform are heterogeneous among companies in the wholesale sector, depending on their operational and cost structures, benefiting more significantly those historically penalized by the cumulative system. Although the analysis focused on three representative companies, which limits the unrestricted generalization of the findings, the results provide a solid basis for the debate on the modernization of the tax system. It is suggested that future research deepen the investigation with more detailed fiscal data and after the effective implementation of the new system, allowing for a more comprehensive assessment of the impacts across different economic sectors.

Bibliographic References

AMORIM, J. E. B. 2021. A extensão do manto da cláusula pétrea do pacto federativo: um estudo sobre o federalismo fiscal e reforma tributária. Cadernos de Derecho Actual, n. 15, p. 589-599. Disponível em: https://www.cadernosdedereitoactual.es/index.php/cadernos/arti-cle/view/1273. Acesso em: 10 abr. 2026.

ANDRADE, M. M. 1999. Introdução à metodologia do trabalho científico. 4. ed. Atlas, São Paulo, SP, Brasil.

BIRD, R. M.; GENDRON, P. P. 2007. The VAT in developing and transitional countries. ed. Cambridge University Press, Cambridge, UK.

BORGES, B. 2023. Carga tributária sobre o consumo no Brasil: evidências empíricas e im-plicações macroeconômicas. FGV/IBRE, São Paulo, SP, Brasil.

BRAZUNA, J. L. R. 2020. Tributação na teoria e no papel. O Papel, v. 81, n. 8, p. 44–45.

BRAZUNA, J. L. R. 2023. O assunto do momento: a reforma tributária. O Papel, v. 8

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

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Tax Management

October 09, 2026

Utilization of ICMS Credits on Intermediate Products: Jurisprudence and Impacts on Corporate Tax Management

The ICMS tax credit regime on intermediate products has gained practical and legal relevance due to the jurisprudential expansion of the functional essentiality criterion and the impacts of its application on corporate tax management. The study analyzed how two industries in the furniture sector located in Rio Grande do Sul applied the understanding of the Superior Court of Justice regarding ICMS credits related to intermediate products, evaluating the conformity of the observed practices with the examined normative and jurisprudential parameters. The investigation was applied in nature and conducted through a multiple case study, with a qualitative and descriptive approach, based on the documentary analysis of fiscal, accounting, and operational information from two medium-sized industries located in Rio Grande do Sul, complemented by the examination of normative, doctrinal, and jurisprudential sources and the development of a checklist of essentiality criteria. The results revealed that recent jurisprudence favored the functional essentiality of the input, allowing the crediting of items consumed or gradually worn out when necessary for the core business activity. However, it was evident that the effectiveness of this regime depended on the companies’ ability to internalize these parameters into uniform classification and documentation criteria. The secure implementation of credit utilization was conditioned less by the existence of legal support and more by overcoming internal filters of economic materiality, classificatory heterogeneity, and evidentiary insufficiency in borderline items, which highlighted the need for consistent fiscal governance.

Keywords: Functional essentiality; Multiple case study; Fiscal governance; Non-cumulative taxation; Furniture sector.

Tax Management

October 09, 2026

Internationalization in the Fabric Processing Industry: A Comparative Study between Presumed Profit and Actual Profit

This study analyzed the tax impacts of internationalization in a Brazilian textile processing industry, comparing the Presumptive Profit and Real Profit regimes and their effects on business competitiveness. The research, of an applied nature and qualitative approach, used a case study based on the analysis of the organization’s economic, fiscal, and operational data for the fiscal year 2025. Tax incentives applicable to exports were examined, such as the exemption of Tax on Industrialized Products (IPI), ICMS, PIS, and COFINS, and the possibility of maintaining tax credits. Comparative scenarios were developed between the regimes, considering the effective tax burden, pricing, cash flow, administrative complexity, and economic viability. The results showed that export operations provided a significant reduction in the indirect tax burden and the maintenance of credits, improving competitiveness. However, the simulations indicated that, even with the utilization of PIS and COFINS credits under the Real Profit regime, the overall tax burden calculated was higher than that of the Presumptive Profit regime, resulting in a lower net profit. It was concluded that remaining in the Presumptive Profit tax system proved more advantageous for the company in the analyzed scenario, and that taxation plays a strategic role in competitiveness, providing subsidies for decision-making in a complex fiscal environment.

Keywords: Tax credits; Tax exemption; Calculation regime.

Tax Management

October 08, 2026

Special Taxation Regime for Real Estate Developments: an Analysis of CARF Rulings

The Special Taxation Regime (RET) applicable to real estate developments was analyzed, comparing it with the regimes of Actual Profit and Presumed Profit, in light of the jurisprudence of the Administrative Council for Tax Appeals (CARF). The research was characterized as qualitative, descriptive, and exploratory. It was developed through bibliographic review, legislative analysis, and documentary examination of five administrative rulings issued between 2018 and 2025, collected from the official CARF portal. The results revealed a predominance of restrictive decisions regarding the application of tax benefits, with a favorable trend towards the National Treasury, especially in defining the tax base and in fulfilling the legal requirements for adherence to the regime. It was identified that CARF adopts a restrictive interpretation of tax benefits and requires formal rigor in the constitution of the affected property. Additionally, a relevant interpretative tension was found between precedents from the Superior Court of Justice (STJ) and the Supreme Federal Court (STF) regarding gross real estate revenue in exchange operations, which represents a structural legal risk for taxpayers. It was concluded that the adoption of RET, although advantageous in terms of simplicity and tax predictability, requires strict compliance with regulatory requirements and continuous monitoring of administrative jurisprudence, with its choice being conditioned by the specificities of the development and the legal risks involved. The research contributed to deepening the analysis of taxation in the real estate sector, offering subsidies for professionals in the field.

Keywords: CARF; Real estate developments; Tax planning; Special Taxation Regime.