Our partner Ana Cláudia Utumi spoke with Valor Econômico about the Brazilian Federal Revenue Service’s new interpretation regarding the IOF tax on risk sacado operations.
The debate intensified after the publication of Decree No. 12,466/2025, which categorized these operations as credit transactions — a move that has been questioned by several tax experts.
According to Ana, this is a “transaction with credit, not a credit transaction.” Therefore, changes to the IOF rate and its application cannot be implemented by decree, but would require a complementary law.
She also points out that, in a 2014 Ruling (Solução de Consulta), the Revenue Service itself stated that IOF does not apply to operations without co-obligation, based on regulations that remain in effect and were not amended by the new decree.
Read the full article: https://valor.globo.com/financas/noticia/2025/05/29/receita-ja-mudou-ao-longo-do-tempo-interpretacao-sobre-risco-sacado.ghtml
