Article

Tax Management

October 05, 2026

Corporate social responsibility and tax citizenship: the asymmetry of institutional recognition

Corporate Social Responsibility and Tax Citizenship: the Asymmetry of Institutional Recognition

Flávia Roberta da Silva Santana; Marcus Vinicius da Silva Nunes

DOI: 10.22167/2675-6528-202602911

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

Corporate social responsibility (CSR) in Brazil has traditionally been associated with voluntary and philanthropic actions, with compliance with tax obligations rarely recognized in this context. The study analyzed how the tax dimension is perceived in the field of CSR, considering the role of tax incentives and the institutional changes of the 2023 Tax Reform, focusing on the relationship between tax compliance and the symbolic recognition of CSR practices. A qualitative, descriptive-exploratory research was conducted through a literature review, legislative analysis, public data, and institutional and ESG reports from six large Brazilian companies. The results indicated that taxation, although materially relevant for public funding, appears in corporate reports mainly in economic-financial, governance, and tax transparency dimensions. The regular payment of taxes remained little recognized as a component of CSR, while voluntary actions received greater emphasis. It was concluded that there is a persistent asymmetry between the material contribution of companies to state funding and their symbolic recognition in the discourse of corporate social responsibility.

Keywords: Corporate Citizen; ESG; Tax Reform; Tax Responsibility; Fiscal Transparency.

1. Introduction

Taxation represents the main mechanism through which the State finances public policies and guarantees the fundamental rights of the population. In the Brazilian context, the tax burden is notably high and complex, which can, in certain circumstances, foster tax evasion and, consequently, harm economic development and social justice.

Historically, corporate social responsibility has been associated with voluntary initiatives, such as donations and sponsorships for cultural, sports, and social projects. Academic literature points out that these philanthropic actions constituted one of the first manifestations of companies’ social commitment (Assis, 2010).

In Brazil, this perspective, which tends to be more restricted, was reinforced by the creation of tax incentives by the State. Laws such as Rouanet, the Audiovisual Law, and the Funds for the Rights of Children and Adolescents (Brasil, 1990; Brasil, 1991; Brasil, 1993) allow part of the tax due to be directed to approved social projects. These mechanisms contribute to associating companies’ social activities with incentivized and more visible actions.

This dynamic consolidates the perception that corporate social responsibility is directly linked to the support of causes with fiscal benefits. In contrast, the regular and transparent fulfillment of tax obligations, which is the continuous basis for financing public policies and state functioning, remains less valued in the CSR discourse (Nascimento, 2007).

Academic literature corroborates the existence of an asymmetry between discourse and what effectively finances public policies. Taxation is a central element in the relationship between companies and society, as it enables the functioning of public institutions and sustains the structure of economic activity (Christensen and Murphy, 2004).

Brazilian studies also relate CSR to fiscal responsibility, indicating that responsible corporate action includes tax contribution (Fadlalah et al., 2012). However, the construction of corporate social responsibility in the country still focuses on voluntary and philanthropic actions, especially those linked to tax incentives.

The regular fulfillment of tax obligations, although it is the main source of funding for public policies, is often treated as a legal duty, rather than a constitutive dimension of CSR. This invisibility of the tax dimension in the institutional recognition of corporate social responsibility reveals a possible asymmetry between what is socially valued and what, in fact, sustains the funding of public policies.

The concept of a citizen company, in turn, encompasses organizations whose contribution to the common good is not restricted to voluntary actions, but includes the correct, continuous, and transparent fulfillment of their tax obligations. Considering that taxes are the main source of funding for public policies and social rights, the neglect of this dimension in the recognition of CSR is a relevant issue.

In parallel with this debate, Brazil is undergoing a process of reorganizing its tax system with the approval of Constitutional Amendment No. 132/2023. Although this reform does not directly aim to redefine corporate social responsibility, its changes in tax collection and compliance mechanisms highlight the role of taxes in financing public policies.

In this scenario, it becomes opportune to revisit how companies’ tax contribution is recognized or not in the debate on corporate social responsibility. The theoretical and practical gap lies in the lack of explicit recognition of tax payment as an integral part of CSR, despite its material relevance for state financing.

This research is justified by the need to deepen the understanding of the asymmetry between the material contribution of taxation to state financing and its symbolic recognition in the field of corporate social responsibility. The study thus seeks to analyze how the tax dimension is recognized in the field of corporate social responsibility in Brazil, considering the role of tax incentives and the institutional changes resulting from the 2023 Tax Reform, focusing on the relationship between compliance with tax obligations and the symbolic recognition of CSR practices.

2. Material and Methods

This research was characterized as qualitative, of a descriptive-exploratory nature, according to Gil’s (2008) approach. The study was based on documentary analysis and bibliographic review, seeking to analyze how corporate social responsibility has been constructed in Brazil, especially regarding the recognition of ethical compliance with tax obligations as a constitutive dimension of CSR.

The temporal scope adopted for the documentary analysis covered the period from December 2023 to December 2025. The initial milestone corresponded to the promulgation of Constitutional Amendment No. 132/2023, which reorganized the Brazilian tax system. The final scope considered the period immediately preceding the start of the practical transition phase of the new model, scheduled for January 2026.

The literature review, in turn, incorporated later references that synthesize academic debates produced throughout the analyzed period, ensuring the inclusion of recent discussions on the relationship between corporate social responsibility and taxation. No rigid temporal delimitation was established for the review, prioritizing relevant and consolidated studies, with a greater concentration of publications from 2010 onwards.

The methodological procedures adopted were divided into four main axes. Firstly, a legislative analysis was carried out, focusing on the reading and comparison of the previous tax system with the new arrangement instituted by Constitutional Amendment No. 132/2023. This analysis emphasized the changes related to collection, compliance, and mechanisms for combating tax evasion.

Secondly, a literature review was conducted, focusing on academic production regarding corporate social responsibility, tax responsibility, fiscal citizenship, business ethics, and tax evasion. The objective was to identify recurring interpretative patterns and theoretical gaps. Searches were performed in academic databases such as Google Scholar and SciELO, using descriptors like “corporate social responsibility”, “citizen company”, “tax incentives”, “philanthropy”, and “fiscal responsibility”.

The initial search resulted in approximately 50 publications, including scientific articles, academic papers, and book chapters. After screening, 12 studies were considered directly relevant to the analysis, excluding works with an exclusive focus on environmental aspects unrelated to fiscal matters, foreign contexts without connection to Brazil, or of a strictly opinion-based nature. These 12 studies were read in full and interpreted qualitatively.

The third axis consisted of the analysis of public data and institutional documents, based on information disclosed by official bodies, such as the Department of the Treasury. The editions of the National Treasury’s Results (RTN) referring to the closings of the fiscal years 2023, 2024, and 2025 were examined, focusing on the collection structure and its role in financing public policies at the federal level.

Finally, the analysis of business practices was carried out through the reading of institutional reports and ESG reports disclosed by large Brazilian companies. Documents referring to the 2024 fiscal year of six companies were examined: Natura &Co, Itaú Unibanco, Magazine Luiza, Cogna Educação, Telefônica Brasil, and Teleperformance. Additionally, the Teleperformance Brasil Environmental & Sustainability Policy was analyzed.

The selection of companies occurred through non-probabilistic intentional sampling, considering the availability of public information in sustainability or institutional reports containing data on social responsibility and corporate governance practices. The study did not aim to establish rankings or comparative performance evaluations, but rather to identify recurring patterns in the discursive construction of CSR and its relationship with the tax dimension.

The data analysis was conducted through qualitative and interpretive content analysis, according to Bardin (2011). The process was structured in stages of pre-analysis, material exploration, and results treatment. In the pre-analysis, an exploratory reading of the corpus was carried out to identify patterns in the approach to CSR and the tax dimension, from which analytical categories were defined.

The analytical categories were based on the literature review and included: (i) tax visibility, to identify the presence and form of presentation of references to taxes in reports (Meira, 2024); (ii) tax compliance and transparency, to examine references to the fulfillment of obligations, tax conduct, and disclosure of information (Fadlalah et al., 2012; Antonik, 2016); (iii) tax incentives and social investment, to identify the association of tax benefits with social projects (Assis, 2010); and (iv) recognition of the tax dimension in CSR, to verify whether the regular payment of taxes is presented as part of corporate social responsibility (Christensen and Murphy, 2004; Davis et al., 2016; Kovermann and Velte, 2021; Araújo et al., 2024; Velte, 2026).

The material was manually encoded by the researcher. The unit of analysis was institutional and ESG reports, and the unit of registration was textual excerpts, indicators, and thematic references related to the tax dimension and CSR. Strictly operational or financial content unrelated to the defined categories, as well as socio-environmental information that did not contribute to the understanding of the tax dimension in CSR, were excluded.

After identifying the relevant records, each occurrence was classified according to the established categories. The qualitative interpretation considered the context in which the contents appeared in the documents and their relationship with the research problem. The coding and interpretation were carried out exclusively by the researcher, without independent double coding.

For data organization, the findings were systematized into a relational analytical structure, which allowed the empirical data to be articulated with the theoretical framework. This structure compared the material basis of state funding with the symbolic recognition of CSR, considering dimensions such as type of social contribution, nature, collective social impact, visibility, and predominant narrative. Additionally, the tax systems (Lucro Real, Lucro Presumido, and Simples Nacional) were characterized in relation to the normative structure, access to tax incentives, tax compliance, and disclosure of CSR practices.

3. Results and Discussion

This section of Results and Discussion integrates the research findings, articulating the legislative analysis, the bibliographic review, public data, and business practices to understand how the tax dimension is recognized in the field of corporate social responsibility (CSR) in Brazil. The results reveal a persistent asymmetry between the material contribution of companies to state financing and their symbolic recognition in CSR discourse, influenced by the role of tax incentives and institutional changes from the 2023 Tax Reform. The discussion is organized into subtopics that reflect the study’s methodological stages, allowing for an in-depth analysis of each dimension.

Legislative Analysis Results

The legislative analysis of Constitutional Amendment No. 132/2023 demonstrated a structural reorganization of the Brazilian tax system, with the replacement of fragmented taxes by a dual Value Added Tax (VAT) model, composed of the Tax on Goods and Services (IBS) and the Contribution on Goods and Services (CBS). This new arrangement aims at the simplification and rationalization of consumption taxation, replacing taxes such as ICMS, ISSQN, PIS, and COFINS. The reform incorporates mechanisms of full non-cumulativeness, the possibility of “split payment”, and intensive use of digital records, which strengthens the compliance and traceability of economic operations, as provided for in Complementary Law No. 214, enacted in 2025.

These elements indicate that the new normative framework expands the capacity for monitoring and transparency of economic relations, creating an institutional environment more favorable to the observation of tax compliance practices. Although the Tax Reform does not directly aim to redefine the parameters of CSR, the strengthening of traceability and fiscal transparency mechanisms can influence, in the medium and long term, how the fulfillment of tax obligations is perceived in the public and institutional debate on CSR. The reform, by repositioning tax collection and compliance as central, questions the traditional construction of CSR, opening space for the incorporation of tax responsibility in this field.

The legislative findings, therefore, indicate that the Tax Reform may contribute to the creation of institutional conditions favorable to the recognition of tax responsibility as a relevant dimension of CSR. However, this recognition has not yet materialized explicitly in the corporate discourse during the analyzed period. The lower tolerance for practices unrelated to the regular fulfillment of tax obligations, reinforced by the new legislation, suggests a paradigm shift that, although incipient, may reconfigure the understanding of companies’ socially responsible performance in the future.

Results of the Literature Review

The literature review revealed that corporate social responsibility in Brazil has historically been associated with voluntary and philanthropic actions, such as donations and sponsorships for cultural and social projects, often linked to tax incentives (Assis, 2010). This perspective is reinforced by state mechanisms that allow a portion of the due tax to be directed to approved projects, consolidating the idea that CSR is linked to causes with fiscal benefits and greater visibility. In contrast, the regular and transparent fulfillment of tax obligations, which is the basis for financing public policies, remains less valued in the CSR discourse (Nascimento, 2007).

Academic literature corroborates the existence of an asymmetry between discourse and what effectively finances public policies. Christensen and Murphy (2004) highlight taxation as a central element in the relationship between companies and society, essential for the functioning of public institutions and the support of economic activity. In the Brazilian context, Fadlalah et al. (2012) relate CSR to fiscal responsibility, indicating that responsible corporate action includes tax contribution. However, the construction of CSR in the country still focuses on voluntary and philanthropic actions, especially those linked to tax incentives, treating tax compliance as a legal duty, rather than a constitutive dimension of CSR.

More recent studies, such as Meira (2024), explore the relationship between corporate sustainability and fiscal transparency, indicating that, despite growing concern with corporate governance, the disclosure of tax information still shows low centrality and standardization in reports. International literature also points out that the relationship between CSR and tax behavior is complex and non-linear, with socially responsible companies not always paying higher effective taxes (Davis et al., 2016). This ambivalence is reinforced by reviews indicating that tax planning occupies a central position in the debate (Araújo et al., 2024; Velte, 2026).

The joint analysis of the selected studies reveals a convergence regarding the expansion of the CSR concept beyond philanthropic actions, but this convergence becomes less evident when the tax dimension is addressed. The lack of consensus on whether socially responsible companies pay more or less taxes, and the low centrality of tax information in corporate reports, suggest a dissociation between the recognition of social practices and tax contribution. This theoretical and practical gap reinforces the need to investigate whether compliance with tax obligations is recognized as part of CSR.

Overall, the analyzed literature indicates that CSR has been predominantly interpreted through voluntary practices and socially visible initiatives, while the regular fulfillment of tax obligations tends to be treated solely as a legal requirement. This pattern reveals a significant gap in the academic debate, as tax contribution rarely appears explicitly as a dimension of corporate social responsibility, a phenomenon that can be understood in light of the literature on the institutional limits of CSR (Schroeder and Schroeder, 2004). The articulation between CSR and tax behavior, although growing, still presents relevant theoretical and empirical gaps.

Results of Public and Documentary Data Analysis

The analysis of public data and institutional documents, based on the National Treasury Reports (RTN) from the National Treasury Secretariat, highlighted the centrality of tax collection for financing public policies. The structure of Brazilian public revenues is predominantly composed of taxes on consumption, income, and economic activity, with revenues administered by the Federal Revenue Service being the main portion of the Central Government’s collection. Taxes such as IPI, CSLL, PIS, PASEP, and COFINS, in addition to social security contributions, constitute the funding base for state activities and social rights.

The analyzed reports demonstrated that the Central Government’s fiscal performance is directly conditioned by the dynamics of tax collection. In 2023, the Central Government’s primary result showed a deficit of approximately R$ 230.5 billion. In 2024, there was a relative improvement, with a deficit of R$ 43.0 billion, and in 2025, the registered deficit was around R$ 61.7 billion. These data show that variations in tax collection directly influence the financing capacity of public policies (Secretaria do Tesouro Nacional [STN], 2023; STN, 2024; STN, 2025), reinforcing the structural and recurrent nature of collection for the maintenance of public services.

The distribution of Central Government expenses between 2023 and 2025 revealed that the largest portion of collected resources is directed towards essential areas. In 2023, social security consumed R$ 914 billion, health R$ 182 billion, education R$ 166 billion, social assistance R$ 254 billion, and public security R$ 13 billion. In 2024, these values were R$ 939 billion for social security, R$ 214 billion for health, R$ 200 billion for education, R$ 279 billion for social assistance, and R$ 15 billion for public security. In 2025, projected expenses were R$ 972 billion for social security, R$ 245 billion for health, R$ 226 billion for education, R$ 286 billion for social assistance, and R$ 17 billion for public security. These figures underscore the structural relevance of tax collection for maintaining essential services to society.

Despite the centrality of revenue collection to the functioning of the State, the material relevance of tax contribution is not proportionally reflected in the symbolic recognition attributed to it in the corporate discourse on CSR. The results of this stage point to a persistent distancing between the material importance of tax collection and its visibility in the symbolic field of corporate social responsibility. This distancing contributes to tax compliance being treated as an implicit prerequisite of business activity, rather than as a socially recognized practice, directly dialoguing with the findings of the literature review.

Analysis Results of Business Practices

The analysis of the institutional and ESG reports of six major Brazilian companies (Natura &Co, Itaú Unibanco, Magazine Luiza, Cogna Educação, Telefônica Brasil, and Teleperformance) revealed that these documents dedicate ample space to the description of social actions, community impact projects, environmental initiatives, and voluntary commitments related to business sustainability. These practices are presented in detail, with indicators of reach, invested values, and institutional narratives that seek to demonstrate social impact, occupying their own sections and associated with the company’s image as a socially responsible agent.

In Teleperformance’s report, for example, the tax dimension is mentioned among the company’s contributions to communities, registering “€366M in income tax paid” in the set of value creation indicators, alongside “€8M in donations to NGOs” and “45,000 hours of volunteer work” (Teleperformance, 2024, p. 8). Although the payment of taxes is recognized as a relevant economic contribution, the document does not expressly call it a corporate social responsibility practice. Teleperformance’s Environment & Sustainability Policy also relates CSR initiatives to the company’s performance as a responsible global corporate citizen, but without explicitly stating ordinary taxation as part of this citizenship.

Similarly, Natura &Co highlights the strengthening of socio-biodiversity communities and the socioeconomic development of the region, reporting that it reached, six years ahead of schedule, the goal of engaging with 45 socio-biodiversity communities (Natura &Co, 2024, p. 92). In contrast to this visibility given to voluntary actions, tax responsibility occupies a secondary role in most of the analyzed reports. The payment of taxes appears indirectly, normally linked to compliance with current legislation, management of regulatory risks, or fiscal control and compliance mechanisms.

In Cogna Educação’s Integrated Report, the heading “Taxes, fees, and contributions” is part of the Direct Economic Value Generated and Distributed Statement, appearing among the components of distributed economic value (Cogna Educação, 2024, p. 132). In another section, the company relates taxation and social initiatives through incentive laws, allocating part of the Income Tax to support culture, sports, and social development (Cogna Educação, 2024, p. 37). In this case, the approximation between taxation and social action occurs through the incentivized allocation of taxes, rather than through ordinary tax collection as a social responsibility practice.

Magazine Luiza, in its demonstration of value generation and distribution, presents its contribution to the State under the heading “Payments to government,” which reached R$ 5.369 billion in 2024 (Magazine Luiza, 2024, p. 90). However, social initiatives receive their own treatment, with donations totaling R$ 3,422,066 reais in private social investment (Magazine Luiza, 2024, p. 54). This arrangement of information in distinct fields reinforces the separation between the tax dimension, presented within the economic-financial scope, and the voluntary actions recognized as an expression of the organization’s social performance.

In Telefônica Brasil (Vivo), the Value Added Statement also presents “Taxes, fees, and contributions” among the components of the distributed economic value, totaling R$ 12.812 billion in 2024 (Telefônica Brasil, 2024, p. 53). The company dedicates a specific section to “Responsible tax performance”, declaring a commitment to paying taxes and their contribution to economic and social progress. However, even while attributing an economic and social contribution to the fulfillment of tax obligations, the document does not expressly characterize it as a corporate social responsibility practice (Telefônica Brasil, 2024, p. 54).

Itaú Unibanco, in its report, states that Private Social Investment (PSI) is an important instrument for promoting social development (Itaú Unibanco, 2024, p. 212). In 2024, 36% of the resources allocated to social investment used funds from tax benefits, including tax incentive mechanisms targeted at different areas. The document establishes a direct relationship between these mechanisms and CSR, stating that tax incentive laws “can contribute to corporate social responsibility projects” (Itaú Unibanco, 2024, p. 214). In this case, the association with CSR arises from the incentivized allocation of resources to social projects, not from the characterization of regular tax payments as a corporate social responsibility practice.

In general, tax references in corporate reports appear associated with economic-financial performance, value distribution, governance, and fiscal transparency. Corporate social responsibility (CSR) practices, in turn, are presented in specific dimensions such as social investment, sustainability, socio-environmental impact, and community relations. This distinction between regular tax payments and the use of tax incentives is relevant, as the association with CSR occurs predominantly through the incentivized allocation of resources to social projects, rather than through the ordinary fulfillment of tax obligations.

The systematization of findings reveals that the material basis of state financing, characterized by regular compliance with tax obligations, is mandatory and continuous in nature, with a collective social impact on the structural financing of public policies and implicit visibility in state revenue collection, being narrated as a legal duty. In contrast, the symbolic recognition of CSR is associated with philanthropic and incentivized actions, voluntary and communicable in nature, with an impact on specific social impact projects, explicit visibility in ESG reports, and a narrative of declared social responsibility. This relational structure highlights the dissociation identified throughout the research.

The analysis of the tax systems (Lucro Real, Lucro Presumido, and Simples Nacional) allows us to understand how different forms of tax classification produce distinct effects on the symbolic construction of corporate social responsibility. Companies subject to the Lucro Real regime have instruments that allow them to direct part of the tax due to incentivized projects, converting a portion of the tax obligation into socially visible actions through tax incentives. In contrast, companies classified under Simples Nacional contribute directly to tax collection without access to equivalent mechanisms for symbolic recognition. This dynamic deepens the identified asymmetry, not only between the material base and symbolic recognition of CSR, but also between different categories of companies within the Brazilian tax system.

This difference is not explained solely by the size of companies or their institutional visibility, but also by the characteristics of the tax systems themselves. In the “Lucro Real” (Actual Profit) regime, part of the tax burden can be directed towards socially visible actions through tax incentives, while simplified regimes operate with direct collection, without this type of public projection. The absence of structured social responsibility reports in these regimes contributes to the low visibility of their contribution, generating a mismatch between their collection relevance and public recognition. Tax compliance, although common to all regimes, is not articulated as a central dimension of CSR in the examined documents.

In summary, the research results indicate that corporate social responsibility, in the Brazilian context, is predominantly constructed from criteria that favor the visibility of voluntary and philanthropic actions, often linked to tax incentives. The regular fulfillment of tax obligations, despite its structural relevance for financing the State and public policies, remains secondary in companies’ institutional discourse, being treated as a legal duty rather than a constitutive dimension of CSR. This persistent asymmetry between the material contribution of taxation and its symbolic recognition in the field of corporate social responsibility is the central finding of the study, evidencing that, although taxation materially sustains the possibility of existence of practices socially recognized as CSR, it is not yet explicitly valued as such.

4. Conclusion

This research analyzed how the tax dimension is recognized in the field of corporate social responsibility in Brazil, considering the role of tax incentives and the institutional changes of the 2023 Tax Reform, focusing on the relationship between compliance with tax obligations and the symbolic recognition of CSR practices. A persistent asymmetry was observed between companies’ material contribution to state financing and their symbolic recognition in CSR discourse. The findings indicated that taxation, although materially relevant for public financing, appears in corporate reports mainly in economic-financial, governance, and fiscal transparency dimensions. The regular payment of taxes remained little recognized as a component of CSR, while voluntary and philanthropic actions, often linked to tax incentives, received greater prominence. It was observed that the 2023 Tax Reform, by strengthening fiscal compliance and traceability, creates an institutional environment more conducive to the recognition of tax responsibility, however, this change has not yet been explicitly reflected in corporate discourse in the analyzed period. The study’s main contribution lies in deepening the understanding of this dissociation, highlighting that tax responsibility, although materially supporting CSR practices, is not yet explicitly valued as such.

The research presents limitations inherent to its qualitative and documentary scope, which does not allow for statistical generalizations or access to the internal motivations of companies, in addition to having focused on large corporations, excluding small and medium-sized enterprises. The analyzed period (2023–2025) also precedes the practical implementation of the Tax Reform, which may have influenced the absence of clearer reflections in corporate discourse. For future studies, it is suggested to investigate the perception of managers of small and medium-sized enterprises regarding the relationship between taxation and CSR, as well as to monitor, over time, the impacts of the Tax Reform on the institutional discourse of Brazilian companies. It is recommended that larger companies include clearer information about their tax contribution in sustainability reports, and that institutional mechanisms for recognizing regular tax compliance be created, such as seals or fiscal criteria in business sustainability rankings, in order to increase the visibility of tax contribution to the financing of public policies.

Bibliographic References

Assis, K.G. 2010. Da filantropia à responsabilidade social. Dissertação de Mestrado em Engenharia de Produção. Universidade Federal de São Carlos, São Carlos, SP, Brasil.

Brazil. 1990. Law nº 8.069, of July 13, 1990. Provides for the Statute of the Child and Adolescent and makes other provisions. Official Gazette of the Union, Brasília, DF, July 16, 1990. Accessed on: Jan. 16, 2026.

Brazil. 1991. Law nº 8.313, of December 23, 1991. Reestablishes principles of Law nº 7.505, of July 2, 1986, institutes the National Culture Support Program (Pronac) and provides other measures. Official Gazette of the Union, Brasília, DF, Dec. 24, 1991. Section 1, p. 30261 – Rouanet Law. Accessed on: Jan. 16, 2026.

Brazil. 1993. Law nº 8.685, of July 20, 1993. Creates mechanisms to foster audiovisual activity and makes other provisions. Official Gazette of the Union, Brasília, DF, 2

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

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September 30, 2026

The offsetting of withholding income tax (IRRF) on service exports is limited by operational and documentary hurdles

The tax credit for withholding income tax (IRRF) on service exports represents a significant challenge in international taxation for Brazilian companies. The diversity of foreign tax systems, the lack of documentary standardization, and the rigorous demands of national legislation hinder credit recognition. The study aimed to analyze the legal, documentary, and operational challenges related to the offsetting of IRRF paid abroad on service exports, considering Brazilian legislation, international treaties, and administrative jurisprudence from CARF. A qualitative, exploratory, and analytical approach was used, through bibliographic review, normative examination, jurisprudence investigation, and a case study in a multinational company. Company X, with service exports totaling R$ 26,647,021.30 in 2025 to 32 countries, was analyzed. The results indicated that the main obstacles lie not in the absence of a legal basis, but in the asymmetry between Brazilian formal requirements, such as official documents, sworn translations, and apostilles, and the operational reality of withholdings. This situation generated a negative IRPJ balance of R$ 10,737,400.49 in 2025, highlighting the economic risk of disallowance. It was concluded that effective IRRF offsetting requires structured tax governance, documentary standardization, and integration between the involved units and areas.

Keywords: Tax offsetting; Service exports; Tax governance; IRRF; International treaties.

Tax Management

September 30, 2026

Structural tax reforms: French experience and implications for the Brazilian system

The taxation of high-value assets is an instrument for promoting fiscal justice, the structuring of which requires a coherent normative and institutional arrangement. The study assessed the contribution of high-value taxation to more equitable economic development and analyzed whether mechanisms for taxing large fortunes or high-value assets constitute a legally viable and economically effective path to fiscal and social justice in Brazil. The research adopted a qualitative, theoretical-descriptive, and analytical-comparative approach, focusing on Brazil and France, using bibliographical, documentary, and macroeconomic and microeconomic indicators. It was observed that the French experience with taxes on large fortunes, such as the ISF and IFI, did not cause major shifts in aggregate macroeconomic indicators, but revealed redistributive potential when supported by robust administrative capacity and international cooperation. In the Brazilian context, the low effective intensity of wealth taxation contributed to the maintenance of wealth concentration. It was concluded that the effectiveness of high-value taxation for fiscal justice depends not only on the creation of new taxes, but on strengthening progressivity, tax administration, adequate measurement of the taxable base, enforcement efficiency, and international cooperation, essential elements for consolidating the Brazilian tax system on more equitable grounds.

Keywords: Fiscal justice; Tax progressivity; Structural tax reform; Taxation of high-value assets; Taxation of large fortunes.