According to the latest report from the Federal Revenue Service, the cap was reached in March 2025, prompting tax authorities to recommend the program's termination to the Joint Budget Committee starting in April
Last week, secretaries and deputy secretaries of the Brazilian Federal Revenue Service (RFB) participated in a public hearing at the National Congress to present a report on tax exemptions granted under the Emergency Program for the Recovery of the Events Sector (Perse).
Enacted through Law No. 14,148/2021, Perse provided reductions in Corporate Income Tax (IRPJ), Social Contribution on Net Profit (CSLL), PIS, and Cofins for a period of five years. However, with the passage of Law No. 14,859/2024, a tax exemption cap of R$ 15 billion was introduced, stipulating that the program would be terminated once this threshold was reached.
According to the latest report from the Federal Revenue Service, the cap was reached in March 2025, prompting tax authorities to recommend the program's termination to the Joint Budget Committee starting in April.
While some lawmakers have questioned the findings presented in the report, the potential discontinuation of Perse as early as next month remains under discussion.
In light of this development, companies benefiting from Perse are advised to assess their individual situations and consider legal avenues to challenge the early termination, based on the following arguments:
- The revocation of the benefit would result in an increased tax burden, which can only take effect after 90 days for contributions or in the following fiscal year for taxes;
- Perse was established with a fixed duration and under specific conditions, meaning it cannot be revoked before its originally scheduled expiration date of December 31, 2026, regardless of the subsequently imposed budgetary cap.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
