The Brazilian Federal Revenue Service (RFB) has issued Interpretative Declaratory Act RFB No. 1 of 22 January 2026 (the Act), which clarifies the allowed deduction of foreign tax paid by a Brazilian company's controlled or affiliated entities abroad (i.e., CFCs), when calculating corporate income tax (IRPJ) and social contribution on net profit (CSLL). The Act clarifies that foreign taxes may …