Brazil Court Opens Tax Credit Door for Manaus Free Zone Firms

FTZ News: A federal court in Amazonas said a company in the Manaus Free Zone can claim PIS and Cofins credits on goods and inputs it buys. The case is No. 1004338-61.2025.4.01.3200. The company had sued the Receita Federal. The court put no reais figure on the credits.

According to Amazonas Direito, which reported the ruling on Oct. 4, a zero rate on the purchase does not, by itself, shut off the credit. The site wrote: “o fato de determinadas compras terem alíquota zero de PIS e Cofins não impede automaticamente o uso dos créditos.” PIS is the social-integration levy. Cofins is the social-security financing levy.

The credit holds if the goods are resold, or go into products, in a later sale that actually owes the two levies. It does not matter whether the supplier is inside the free zone or outside it. There is no credit if the resale or the finished good is also zero-rated, exempt, or not charged PIS and Cofins.

The company may offset credits on purchases back to March 2023, adjusted by the Selic rate. The offset has to wait until the ruling is final, and it has to follow Receita rules. The tax office can check the arithmetic and whether the credits sit on sales that were taxed.

The story does not name the company, the judge or the law the court used. It does not say if the Receita will appeal./.