On August 22, 2025, Ordinance MF No. 1,862 was published and is now in effect, establishing exceptional measures due to the imposition of additional tariffs by the United States of America on Brazilian exports.

The regulation provides conditions for priority in the refund and reimbursement of tax credits and for the deferral of the due date of federal taxes and installments related to the Union's active debt, establishing:

Priority in refund/reimbursement requests:
Exporting companies (including suppliers to trading companies) will have priority in the analysis of processes submitted via PER/DCOMP.
It covers both previously submitted requests and new requests filed within six months of the publication of the Ordinance, extendable for an equal period.

Extension of deadlines for federal taxes:
Taxes due in August 2025: extended to the last business day of October 2025.
Taxes due in September 2025: extended to the last business day of November 2025.
Includes taxes administered by the Federal Revenue Service and installments of agreements or transactions entered into with the PGFN.
The measure does not apply to Simples Nacional.

Eligibility criteria:
Companies that prove they were affected by the executive order of 07/30/2025 (list of NCMs to be published by MDIC).
A minimum percentage of 5% of gross annual revenue (Jul/2024 to Jun/2025) from exports to the USA.
Also includes individual entrepreneurs, micro-entrepreneurs (MEIs), and rural producers with a CNPJ.

These measures aim to mitigate the economic impacts of additional tariffs, ensuring greater liquidity for exporting companies through tax deferral and accelerated credit refunds.

Affected exporting companies should pay attention, checking whether their operations are included in the NCMs published by MDIC, reviewing any pending or future refund/reimbursement requests, and adjusting their cash flow according to the new deadlines established, if they meet the requirements of Ordinance MF No. 1,862/2025.

The Dupont Spiller Fadanelli Advogados team is monitoring the matter and is fully available to clarify any questions on the subject.