TAXATION BEFORE AND AFTER THE TAX REFORM IN VERTICAL INTEGRATION CONTRACTS IN BRAZILIAN AGRIBUSINESS

Abstract

This paper analyzes the tax burden on vertical integration contracts in the Brazilian agribusiness sector, highlighting changes resulting from the enactment of Law No. 13,288/2016 and the impact of the Tax Reform (Constitutional Amendment No. 132/2023 and Complementary Law No. 214/2025). It initially addresses the legal development of these contracts, formerly considered atypical and marked by legal uncertainty, now recognized as essential tools in coordinating productive chains. Subsequently, the study examines the traditional tax structure, known for its complexity and diversity of taxes, which posed challenges to tax planning and the competitiveness of integrated enterprises. The paper then assesses the effects of the Tax Reform, which introduced a differentiated regime for integrated rural producers and cooperatives, including presumed credits, reduced rates, and mechanisms aimed at neutrality and non-cumulativity. It concludes that while the reform aims to simplify and modernize the tax system, its transition generates new operational challenges, requiring efficient tax management and public policies geared toward safeguarding rural producers.