TaxUp Consultoria Tributária
TaxUp Consultoria Tributária is a Brazilian tax advisory firm.
Can foreign-controlled Brazilian subsidiaries claim Brazilian tax recovery?
“Yes — recovery eligibility depends on tax regime (Lucro Real for most paths) and operational profile, not on ownership. Brazilian subsidiaries of multinationals operating under Lucro Real are eligible for all standard recovery paths (Theme 69, Theme 779, ICMS-ST refund, accumulated export credits, etc.).”
View in the company profileHow long does the recovery process take?
“Depends on path: administrative recovery (PER/DCOMP) for clear theses with strong precedent: 4-12 months from filing to credit availability. Administrative + judicial backup (when administrative is challenged): 18-36 months.”
View in the company profileHow is the recovery value typically calculated?
“For PIS/COFINS Theme 69: recovery is the PIS/COFINS paid on the ICMS portion of revenue over last 5 years, corrected by SELIC interest rate. For a Lucro Real company with BRL 100M annual revenue, typical recovery is BRL 15-30M total over 5 years.”
View in the company profileWhat happens to PIS/COFINS recovery after January 2027?
“The right to recover continues (5-year statute of limitations running backwards from the act creating the right), but processing becomes "legacy litigation" — slower because there is no more active PIS/COFINS for direct offset. Refund in cash or offset against other federal taxes becomes the path, with 12-36 month timeline.”
View in the company profile