On 9 October 2026, the Receita Federal launched Operation Inflamável II, targeting improper use of PIS/Pasep and Cofins tax credits in the resale of diesel oil, gasoline, and ethanol. The operation involves a total credit volume exceeding BRL 5 billion, indicating a large-scale scheme where taxpayers allegedly claimed input credits on fuel purchases that were not eligible under the non-cumulative regime. The investigation focuses on distributors and retailers who manipulated tax documentation to reduce federal tax liabilities. This action underscores the government’s intensified scrutiny of the fuel sector, which has historically been prone to tax evasion due to complex supply chains and high transaction volumes. The Receita Federal stated that the operation includes cross-referencing electronic invoices (NF-e) and fiscal SPED records to identify discrepancies.
Key Takeaways
- Massive Credit Volume: The BRL 5 billion in questioned credits represents one of the largest fuel sector tax investigations in recent years, highlighting systemic risk in the supply chain.
- Sector-Wide Impact: Fuel distributors and retailers must review their credit appropriation methodologies to ensure compliance with the non-cumulative PIS/Cofins rules, particularly regarding the acquisition of goods for resale.
- Enforcement Trend: The operation signals a broader enforcement strategy combining data analytics and joint operations with other agencies (ANP, state tax authorities) to combat tax leakage in sensitive sectors.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement