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Tax reform

On the IBS regulation and refunds under the tax reform

Charles W. McNaughton
Conjur · May 7, 2026
Originally published on Conjur on May 7, 2026. Atualidades Tributárias column, ConjurRead on Conjur
In 1 minute
  • Article 486, III, of the IBS Regulation allows refunds to be denied while an IBS assessment is still being challenged administratively.
  • The author argues the rule breaches legality, the right of defence and article 146, III, “b”, of the Constitution by treating a contested debt as enforceable.
  • Exporters with credit balances are hit hardest; the article calls for the regulation to be adjusted through dialogue with the Steering Committee and the Federal Revenue.

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Charles W. McNaughton · Founding Partner

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