Executive summary: Constitutional Amendment 132/2023 preserves Manaus Free Trade Zone (ZFM) incentives through 2073, but the shift to CBS/IBS demands tailored compliance plans, PPB updates, and ESG integration. Companies that build a 2024-2032 timeline, compliance playbooks, and regulatory monitoring gain legal certainty and competitiveness.
📋 Índice
Market benchmark: Suframa, Migalhas, and consulting firms (Thomson Reuters, Deloitte) summarize incentives yet lack detailed PPB, contract, and ESG plans. This guide merges a timeline with compliance steps and ESG metrics to surpass competitor coverage.
ZFM outlook under the Tax Reform
- CA 132/2023 (Art. 92) keeps incentives through 2073.
- PLP 353/2023 outlines ZFM-specific CBS/IBS rules.
- Decree 11.546/2023 and Suframa Ordinance 44/2025 set current incentive requirements.
2024-2032 timeline
| Year | Regulatory milestone | Recommended actions |
|---|---|---|
| 2024 | Expected approval of PLP 353/2023 | Update PPB, review supplier contracts |
| 2025 | Publication of CBS/IBS incentive lists | Validate CNAE/NCM, adjust ERP |
| 2026 | CBS/IBS pilot (1%) | Test crediting, review Suframa reports |
| 2027-2032 | Rate escalation | Track state/municipal incentives, plan investments |
Incentives that remain and adjustments required
| Incentive | Status | Critical points |
|---|---|---|
| IPI reduction/exemption | Maintained | Prove PPB and production processes |
| PIS/Cofins reduction | Converted into CBS credits | Review invoices and tax classifications |
| State ICMS incentives | Preserved via agreements | Update state accords and FEZIM rules |
| Special regimes (ZPE, RECOF) | Can be combined | Integrate controls with CBS/IBS |
Tax compliance plan for ZFM
- PPB inventory: Keep documentation updated and digitally archived.
- Fiscal data room: Invoices, technical reports, contracts, Suframa filings.
- Internal procedures: Policies for input control, internal audits, checklists.
- Regulatory monitoring: Assign staff/consultancy to track Suframa ordinances and related legislation.
CTA: Download the ZFM Compliance Playbook 2026 (PDF with flowcharts and checklists).
Sources: CA 132/2023; Decree 11.546/2023; Suframa Ordinance 44/2025; PLP 353/2023; CNI report “ZFM & Reform” (Mar 2025).
Competitive comparison: We convert PPB requirements into operational steps, while public materials merely emphasize updates. Our guide couples fiscal planning with ESG/governance—rare among competitors.
Contract structuring and supply chain
- Review contracts with non-ZFM suppliers to secure incentive passthrough.
- Insert clauses on incentive preservation and documentation duties.
- Implement a logistics risk matrix (transport, storage, customs).
- Evaluate technology-transfer and shared-service agreements.
Tax planning 2026-2032
- Model investment and credit scenarios under CBS/IBS.
- Assess corporate structures (regional holdings, shared-service centers).
- Integrate federal, state, and ESG-related incentives.
- Map opportunities in green/digital economy (Informatics Law, Law 14.300/2022).
Benchmark: FIEAM (2025) and PwC reports highlight digitalization and renewable-energy investments as competitive differentiators. Use these insights to set goals and metrics.
Environmental compliance and ESG
- Meet sustainability standards required by Suframa, Ibama, and investors.
- Include ESG goals in fiscal reports and PPB submissions.
- Launch renewable-energy, reverse-logistics, and social-impact projects.
Competitive edge: Unlike generic ESG pieces, we align fiscal planning with green incentives and reporting frameworks (GRI, SASB, TCFD).
Frequently asked questions
- Are incentives ending? No. They are guaranteed until 2073 but demand strict compliance.
- Do service companies get incentives? Yes, but with specific requirements—review PPB and related laws.
- How do CBS/IBS credits interact? They coexist with ZFM incentives if documentation is solid.
- What changes in PPB? Rules will be updated for new technologies; expect further ordinances.
- How to handle imports via ZFM? Reinforce customs documentation and inventory controls.
Next steps
- Conduct a regulatory/tax diagnostic within 60 days.
- Review PPB documentation and production schedules.
- Update supplier/partner contracts.
- Implement compliance routines and regulatory monitoring.
- Plan 2026-2032 investments with CBS/IBS scenarios.
Related articles:
– Green-economy incentives
– CBS/IBS for exporters
– Global minimum tax 15%
Legal references
- Constitutional Amendment 132/2023.
- Decree 11.546/2023 (ZFM incentives).
- Suframa Ordinance 44/2025.
- PLP 353/2023.
- STF ADI 310 (ZFM incentive preservation).
- AGU Opinion 00001/2024 (compatibility with the reform).
Need to shield your ZFM operation? FDS Tributário updates PPB, builds compliance playbooks, plans investments, and monitors every regulatory change.
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