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SUDAM and SUDENE: Brazil's Regional Tax Incentives for the Amazon and Northeast

Short answer. Companies running approved projects in Brazil’s Legal Amazon (SUDAM) or Northeast (SUDENE) development regions can claim a reduction of up to 75% of their corporate income tax (IRPJ) on the profit from the incentivized activity — cut to 67.5% for projects approved from 2026 (see below). For a foreign manufacturer choosing where to locate, these regional incentives can materially change the after-tax economics.

What the incentive is

SUDAM (Superintendência do Desenvolvimento da Amazônia) and SUDENE (Superintendência do Desenvolvimento do Nordeste) administer regional development incentives. The headline benefit is a 75% reduction of IRPJ (with the CSLL not covered) on the profit derived from an approved project in priority sectors, for a defined period. [Source: MP 2.199-14/2001; Lei 9.532/1997 — Planalto]

What changed in 2026. Lei Complementar 224/2025 applied a 10% linear reduction to federal tax benefits, which cuts the headline SUDAM/SUDENE reduction from 75% to 67.5%. The full 75% is preserved only for projects approved by the federal government and already in execution by 31 December 2025 (the “onerous condition” exception). A project modelled today therefore gets 67.5%. [Source: Lei Complementar 224/2025 — Planalto; Receita Federal Q&A]

This is an income-tax incentive tied to a specific, approved investment — not an automatic benefit of being located in the region.

Who qualifies

The benefit targets projects in priority sectors for regional development (set by regulation), located in the SUDAM or SUDENE coverage areas, that obtain prior approval. The company must keep the incentivized activity’s results segregated and meet the regime’s conditions throughout the benefit period. [Source: SUDAM; SUDENE — gov.br]

How it interacts with the 2026 reform

The SUDAM/SUDENE benefit is an IRPJ (income-tax) incentive — it is not part of the IBS/CBS consumption-tax reform and is not replaced by it. (The Manaus Free Trade Zone, a separate Amazon regime, has its own treatment under the reform.) Income-tax incentives and consumption-tax reform run on different tracks. [Source: EC 132/2023; LC 214/2025 — Planalto]

Practical takeaway

If a Brazilian project could plausibly sit in the North or Northeast, the 75% IRPJ reduction is worth modeling early — it is one of the few large, location-driven tax levers in Brazil. But it is conditional and approval-based: build the application, sector eligibility and ongoing compliance into the plan, and confirm the current rules with the relevant superintendency before committing.

FAQ

What do SUDAM and SUDENE offer? A reduction of up to 75% of IRPJ on the profit from an approved project in the Amazon (SUDAM) or Northeast (SUDENE) regions.

Does it cover CSLL too? The headline 75% reduction applies to IRPJ; it does not reduce CSLL.

Is it automatic for companies in the region? No — it requires an approved project in a priority sector and ongoing compliance with the regime.

Sources

Official sources reviewed for this brief: the law granting the regional IRPJ reduction (MP 2.199-14/2001; Lei 9.532/1997) and the regional development superintendencies (SUDAM and SUDENE).

FS
Written by

Felipe Scholante

Brazilian tax and customs lawyer, managing partner of Scholante Advocacia and founder of Brazil Tax Brief. Felipe advises companies on Brazilian taxation, tax reform, customs matters and business regulation.

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