Lula Signs Taxpayer Code, Vetoes Deep Relief for Highly Rated Payers

Overview

• President Luiz Inácio Lula da Silva sanctioned Lei Complementar nº 225 creating the Taxpayer Code with five vetoes published in the Diário Oficial.
• The vetoes removed measures such as up to 70% discounts on fines and interest under Sintonia, the use of tax-loss credits to reduce debts, 120‑month repayment terms, and broader flexibility to swap judicial deposits for guarantees, citing the Fiscal Responsibility Law and the 2026 budget guidelines.
• The law’s core remains in force, including compliance programs Confia, Sintonia and OEA that offer simplified treatment and encourage self-regularization for cooperative taxpayers.
• The statute defines the ‘devedor contumaz’ and imposes tougher consequences, with federal reporting citing thresholds above R$ 15 million and over 100% of known assets, plus bans on tax benefits, public procurement and some avenues of judicial relief.
• The decision followed tension between Receita Federal and government legal bodies (AGU/PGFN) as business groups and parliamentary fronts urged full approval, and Congress can now decide whether to sustain or overturn the vetoes.