Executive Secretary of Finance, Dario Durigan, explained that the veto was due to a provision in the Budget Guidelines Law that does not allow the approval and distribution of new benefits
The president (PT) vetoed sections relating to Football Corporations (SAFs), the Complementary Law Project (PLP) nº 108/2024, the last stage of tax reform regulation. The project also creates the Goods and Services Tax Management Committee, the body responsible for managing and operationally coordinating the new tax that will be shared between states, the Federal District and municipalities.
One of the vetoed sections refers to the reduction of taxation for with equivalence for Brazilian clubs. In the first complementary law that regulated the tax reform (nº 214/2025), increases in tax rates on Football Limited Companies were foreseen. The legislation provided for the payment, from 2027, of a total rate of 8.5%, of which 4% for Corporate Income Tax (IRPJ), Social Contribution on Net Profit (CSLL) and Social Security; 1.5% Social Contribution on Goods and Services (CBS) and 3% Tax on Goods and Services (IBS). During the processing of PLP 108, an agreement was reached between the parties to maintain the current taxation of 3%, 1% and 1%, respectively, totaling 5%.
Lula, however, vetoed the device that reduced the IRPJ, CSLL and Social Security rates from 4% to 3%, but maintained the CBS and IBS rates reduced by the National Congress. As a result, the total burden of SAFs will be 6%.
Another section included by parliamentarians removed, during the first five years of the SAF’s constitution, athletes’ pass rights from the basis of calculation of the society’s regime. “During the first five years, the revenue from the sale of the player would not be included in the calculation base. With the veto, this device disappears”, explained advisor João Nobre, from the Ministry of Finance.
Finally, Congress tried to equate sporting activities (football, volleyball, athletics, etc.) to the specific SAFs regime, applying the rates to sporting activities.
Football Societies are a new legal model created by law in 2021 for football clubs, aiming to professionalize management, attract investment and modernize the sector, with a focus on professional football.
“In general, there was an understanding that, as the Football Specific Taxation Regime, TEF, does not only cover IBS and CBS, but has repercussions for other federal taxes, it could lead to a waiver of revenue for other taxes. And, this was the main reason for this veto”, argued João Nobre.
The Executive Secretary of Finance, recalled that there is a provision in the Budget Guidelines Law (LDO) that does not allow the approval and distribution of new benefits. “This is the reason for the veto of this reduction in the SAF”, he explained.
Ten vetoes
The Ministry of Finance reported that a total of 10 provisions of PLP 108 were vetoed, some of which were detailed in the technical conference on Tuesday (13). The sanction and justifications for the vetoes must be published in the regular edition of the Official Gazette of the Union (DOU) this Wednesday (14).
Another veto refers to the inclusion in the list of foods subject to a 60% reduction in IBS and CBS rates. “What happened is that there was the inclusion of natural foods, natural liquids, composed of vegetables, fruits, even if liquids. This generic device that was included led to a great concern that it could be covering more things than Parliament’s intention”, explained Nobre. “And precisely because it is not focused, it could even generate concerns about competition with other healthier substitutes”, he added.
*With information from Estadão Conteúdo
