by Beirigo, Giovani – Partner at Baum, Beirigo & Milani Lawyers
Expanding into Brazil requires a clear understanding of the country’s two primary corporate structures: Sociedade Anônima (S.A.) and Sociedade Limitada (Ltda.). These roughly correspond to a corporation and a limited liability company, respectively. Choosing the appropriate structure is a strategic decision that affects taxation, governance, compliance obligations, and even public perception . This analysis provides a detailed comparison of S.A. vs. Ltda., with insights from consultancy reports and market studies, real-world examples of foreign companies in e-commerce, industrial, and retail sectors, and an overview of regulatory aspects (taxation, shareholding structure, labor laws). The goal is to guide business decision-makers in selecting the optimal structure and adapting their strategies for success in the Brazilian market.
Overview of S.A. and Ltda. in Brazil
In Brazil, most foreign investors establish operations either as an Ltda. or an S.A. . Both structures offer limited liability protection – shareholders or quotaholders (in a Ltda.) are generally only liable up to the amount of capital they invested . However, there are key differences in complexity and use cases. The Ltda. is by far the most common vehicle for subsidiaries and joint ventures because it is simpler to form and operate . In fact, “sociedade limitada” is considered the best choice for the large majority of businesses entering Brazil – it is widely used by companies of all sizes, from small design firms to large multinationals . An S.A., on the other hand, involves a more robust corporate governance structure and is often adopted by larger enterprises or those requiring a more complex ownership model . Crucially, an S.A. is the only option for companies that intend to publicly trade shares or issue certain types of securities in Brazil, as it can register with the Brazilian Securities Commission (CVM) if it becomes a publicly-held corporation .
Legal Framework: Limitadas are primarily governed by the Brazilian Civil Code (Law 10,406/2002), with supplementary application of the Corporate Law (Law 6,404/1976) if the company’s articles of association so allow . S.A.s are governed by the Corporate Law (Law 6,404/76 and its amendments) and must adhere to its more detailed rules on governance and disclosure. In practice, this means S.A.s have more formal requirements, whereas Ltdas enjoy greater flexibility so long as they meet basic legal standards.
Key Differences Between S.A. and Ltda.
Both structures enable foreign companies to operate in e-commerce, industry, or retail, but they differ in setup, governance, and ongoing obligations. Below is an outline of the main differences:
• Ownership and Shareholding Structure: An Ltda. can be formed with a minimum of one only partner ou multiple partners (called quotaholders), who may be individuals or companies of any nationality . (Recent legal updates even allow single-partner Ltdas under certain conditions, simplifying wholly-owned subsidiaries.) Ownership in a Ltda. is expressed in quotas (quotas), each with a nominal value. Quotas are not freely transferable without amending the articles of association, and any change in ownership must be registered at the local commercial registry (Junta Comercial) . In contrast, an S.A.requires at least two shareholders and has its capital divided into shares . Shares can be transferred relatively easily via stock transfers, and an S.A. can create different classes of shares (e.g. voting and non-voting, preferred shares) to attract investors . This makes S.A.s more suited for ventures that might seek broader investment or eventually go public. Notably, an S.A. may be privately held (fechada) or publicly traded (aberta); only the latter must register with CVM and comply with market disclosure requirements .
• Corporate Governance and Administration: Ltdas have a simpler governance structure. They are managed by one or more administrators (gerentes), who must be individuals residing in Brazil . There is no requirement for a board of directors in a Ltda.; governance can be handled through quotaholders’ decisions recorded in meeting minutes. In fact, a Ltda. can be managed by a single director, appointed in the articles of association, with an indefinite term if so desired . S.A.s, on the other hand, have a more complex, multi-tier governance framework . At minimum, an S.A. must have an executive board (Diretoria), composed of at least two executive officers who are individuals resident in Brazil . If the S.A. is publicly traded or if mandated by its bylaws, it also needs a board of directors (Conselho de Administração) with at least three members (who can be non-residents) . Additionally, S.A. law provides for a fiscal council (Conselho Fiscal) and audit committee in certain cases – though these are optional for private companies, they become mandatory for public companies . The governance formality in S.A.s means decisions are made via shareholder meetings, and certain decisions (e.g. approving financial statements, electing directors, amending bylaws) must happen in Annual General Meetings . This robust framework can enhance transparency and control, which is often beneficial for larger operations or joint ventures, but it introduces more bureaucracy for day-to-day management.
• Compliance and Disclosure: Because of their simpler nature, Ltdas face fewer reporting requirements. They are not obliged to publish their financial statements publicly , which keeps administrative costs lower and financial information private. S.A.s are subject to more stringent compliance: annual financial statements must be prepared and, in many cases, published in the official gazette or a widely circulated newspaper (though recent legal reforms have allowed electronic publication to reduce costs). Even privately-held S.A.s traditionally had to follow these publication rules, whereas Ltdas do not, making the S.A. slightly more burdensome on the regulatory side . Furthermore, an S.A. is required to maintain formal corporate books (share register, minutes of general meetings, attendance book, etc.), reflecting its higher level of regulation . By contrast, while a Ltda. should keep minutes of important decisions, it often operates with less formality in practice .
• Capital Requirements and Finance: There is no minimum capital for either form in general law, except in specific sectors or activities that require it. However, S.A.s have some financial rules: for instance, upon incorporation of an S.A., at least 10% of the share capital must be paid in (in cash) to a bank account , and corporate law requires setting aside a legal reserve (usually 5% of annual net profits) until it reaches 20% of capital – a practice not mandated for Ltdas. Ltdas offer flexibility in capital contributions and subsequent capital increases without many formalities; they can also permit disproportional profit distribution if all quotaholders agree (allowing, for example, a partner with fewer quotas to receive a larger share of profits) . S.A.s must follow stricter rules on profit distribution, including the concept of a mandatory dividend (often 25% of profits or as set in the bylaws) to shareholders, proportional to their shareholding , unless the shareholders unanimously decide otherwise or the corporation qualifies for an exception in a given year. Fundraising is another consideration: an S.A. has more avenues for raising capital (it can issue additional shares, debentures, or other securities), whereas a Ltda.’s ability to bring in new investors is limited to adding new quotaholders via an amendment to the contract. If a foreign company anticipates needing to raise significant local capital or invite many investors, the S.A. structure may be more suitable despite its complexity.
• Tax Regime Options: In terms of taxation, both S.A.s and Ltdas are treated similarly by tax authorities, paying corporate income tax (IRPJ) and social contribution on net profits (CSLL) at identical rates , as well as other taxes like PIS/COFINS on revenue and ISS or ICMS on sales, depending on the business. However, Ltda. companies have an additional option not available to S.A.s: qualifying small Ltdas can opt for the Simples Nacional regime – a simplified tax system for small businesses . This regime streamlines and reduces tax payments by consolidating several taxes into a single monthly payment, but it is subject to strict revenue limits and certain eligibility criteria (for example, as of this writing, annual gross revenue must generally not exceed BRL 4.8 million). Importantly, companies with foreign ownership were historically barred from Simples Nacional, though current rules allow it if the foreign partner is an individual resident in Brazil . In practice, most foreign-controlled ventures will exceed the size limits or not qualify for Simples, so they will choose between Brazil’s Lucro Presumido (Presumed Profit) or Lucro Real (Actual Profit) tax regimes. Both Ltdas and S.A.s can elect Lucro Presumido if they meet the criteria (e.g. revenue under a certain threshold, currently BRL 78 million/year), which simplifies tax calculations by applying a deemed profit margin . Larger companies or those in certain sectors must use Lucro Real, which involves accounting for actual profits quarterly or annually and is often more complex. The key takeaway is that the choice of S.A. or Ltda. does not inherently change corporate tax rates, but it can affect which tax regimes are available and the complexity of compliance (since an S.A. cannot use Simples Nacional at all ). All companies, regardless of type, must also register any incoming foreign capital with the Central Bank of Brazil (through the RDE-IED system) and comply with transfer pricing and other tax rules applicable to cross-border transactions.
• Labor and Employment Considerations: Brazil’s labor laws (the Consolidation of Labor Laws – CLT) apply equally to S.A.s and Ltdas. There is no distinction in labor obligations based on the corporate form – employees enjoy the same protections and benefits under the law, such as mandatory employment contracts, social security and severance fund (FGTS) contributions by the employer, overtime rules, and generous paid leave. Foreign companies must be prepared for Brazil’s notoriously rigorous labor regime, sometimes referred to as part of the “Custo Brasil” (“Brazil cost”) of doing business . This includes strong job security provisions and active labor courts. Notably, many companies face labor lawsuits as a routine matter, and courts tend to be protective of employees . Therefore, irrespective of choosing Ltda. or S.A., a new entrant in the Brazilian market should implement strict compliance with labor regulations and consider professional HR and legal support to navigate hiring, contracts, and terminations properly. One structural point to note is that management hiring is impacted by the corporate form: a foreign parent company must appoint at least one local Brazilian-resident individual as a managing director (administrator) for an Ltda. , or at least two local officers for an S.A. . This requirement means companies often need to either relocate a trusted executive to Brazil (after obtaining the proper work visa) or hire a qualified Brazilian national for these roles. Ensuring these managers understand local labor laws and corporate practices is crucial for smooth operations. In summary, labor laws do not favor one structure over the other, but S.A.s – often being larger enterprises – might have greater exposure to workforce management challenges simply due to their scale. All companies should budget for labor costs and benefits (which can add roughly an extra 70-80% on top of gross salaries, when considering taxes and mandatory benefits) and factor in the complexity of compliance when planning their Brazilian expansion .
Insights from Consultancy Reports and Market Studies
Multiple market entry guides and consultancy studies underline that most foreign investors begin with a Limitada structure when entering Brazil, unless specific factors push them toward an S.A. . According to a CMS Brazil market entry report, limitadas are “by far the most commonly used vehicles for subsidiaries … because they are simpler and cheaper to operate.” This simplicity is a significant advantage in a country known for bureaucracy and complex regulations. Consultancies note that forming a Ltda. typically involves fewer steps and lower costs: there is no need to set up a formal board or publish financial statements, and changes in ownership or capital are handled through relatively straightforward amendments at the state commercial registry . Because of this, even large multinational corporations often start as Ltdas to establish a foothold quickly and with minimal administrative overhead.
However, studies also highlight scenarios where an S.A. is beneficial despite the extra complexity. Deloitte’s international tax highlights for Brazil, for instance, mention that both Ltdas and S.A.s are available, but S.A.s may be preferred for larger investments or when the business model contemplates many shareholders or future public fundraising . Similarly, law firm reports (e.g. from DLA Piper and Hogan Lovells) emphasize that while an Ltda. suits most needs, an S.A. provides a more structured framework that might appeal to foreign investors looking for corporate governance akin to their home country corporations . The Brazilian Business Law Guide for Foreign Entrepreneurs notes that an S.A. is often chosen when a company aims to operate on a larger scale or under stricter governance standards, as might be required by venture capital funds or joint venture partners.
Market studies in the e-commerce sector indicate that fast-growing startups initially set up as Ltdas can convert to S.A. later when seeking substantial venture capital. Brazilian law allows a company to change from Ltda. to S.A. as it grows , and this transition is common in the tech sector once a startup matures. For example, a fintech or online retail startup might begin as “XYZ do Brasil Ltda.” and only become an S.A. when preparing for an IPO or a large Series C funding round. Consultancies often recommend this phased approach: start lean as an Ltda., then upgrade your corporate structure when needed. This strategy avoids unnecessary bureaucracy in the early stages and only incurs the higher governance costs of an S.A. when the company is ready to reap the benefits (access to capital markets, enhanced credibility, etc.).
From a tax perspective, accounting firms point out that the choice between Ltda. and S.A. does not change tax liabilities, but they remind foreign investors about the Simples vs. Presumido vs. Real profit regimes discussed earlier. A PwC report on Brazilian expansion suggests closely evaluating if the business could qualify for Lucro Presumido (which simplifies bookkeeping) in the initial years – if so, that can be used under either Ltda. or S.A., though most new entrants will simply default to Lucro Real due to revenue scale. Another insight from consultants is to consider Brazil’s transfer pricing and tax complexity: whichever entity type is chosen, companies must implement robust accounting practices, as Brazil’s tax authorities scrutinize cross-border transactions heavily. While not directly tied to S.A. or Ltda., maintaining compliance (with support from local tax advisors) is part of adapting to the market.
Overall, consultancy guidance converges on a clear message: use the Ltda. as the default unless a compelling strategic reason exists for an S.A. . Those strategic reasons might include the need for a complex shareholder structure, regulatory requirements in certain industries, or plans to access public capital. Even then, many companies initially incorporate as an Ltda. and only switch to S.A. when those needs become imminent.
Real-World Examples: Company Choices in Practice
Looking at how foreign companies in different sectors have structured their Brazilian subsidiaries provides practical insight:
• E-commerce/Tech Sector: The majority of foreign tech and e-commerce entrants operate as Ltdas. For instance, Amazon’s main Brazilian entity is Amazon Serviços de Varejo do Brasil Ltda., reflecting the typical choice of a limited company for a wholly foreign-owned operation. Similarly, Google’s and Facebook’s Brazilian subsidiaries are Google Brasil Internet Ltda. and Facebook Serviços Online do Brasil Ltda., respectively, both Ltdas. These companies chose the Ltda. format to avoid unnecessary formalities – they did not need to raise capital locally or have a broad shareholder base, since the parent company provides funding and oversight. Operating as an Ltda. allowed them to establish quickly and focus on business growth while keeping compliance manageable. Despite being Ltdas, these subsidiaries are still large in scale and impact; the corporate form did not impede their rapid expansion in Brazil’s market.
• Industrial/Manufacturing Sector: In heavy industry and manufacturing, we see examples of both structures. Many long-established multinationals are Ltda. – for example, General Motors do Brasil Ltda. has been operating since 1925 as a wholly owned subsidiary of GM . The Ltda structure suits GM because it is wholly controlled by the parent, and there was no need to list shares or take on local investors. Volkswagen do Brasil Ltda. and Ford Motor Company Brasil Ltda. are similar cases, using the Ltda. model to maintain simplicity in governance while the foreign parent holds 100% ownership. On the other hand, Renault do Brasil S.A. is an interesting counterexample . Renault’s Brazilian arm is structured as an S.A. (though a closed-capital one, not publicly traded). This choice was influenced by a partnership with the state of Paraná when establishing its manufacturing complex – the government took a temporary equity stake, which made the S.A. format suitable for defining share ownership and rights clearly . After Renault gained back full control, it retained the S.A. form, possibly for internal policy consistency or future flexibility. Another example is Furukawa Industrial S.A. Produtos Elétricos, the Brazilian subsidiary of a Japanese cable manufacturer, which operates as an S.A. to align with the corporate governance standards of its global operations . These cases show that in industrial ventures, if joint ventures or government partnerships are involved, or if the company wants a more formal structure, an S.A. can be chosen; otherwise, an Ltda. is often sufficient and simpler.
• Retail Sector: Large foreign retailers have taken different approaches depending on expansion strategy. Walmart Brazil, during its time under Walmart’s ownership, was organized as WMS Supermercados do Brasil Ltda., consistent with the pattern of a private subsidiary (it did not issue shares to the public while Walmart was the sole owner). Carrefour, by contrast, eventually listed its Brazilian operations on the stock exchange – it reorganized part of its business into an S.A. named Atacadão S.A. (Carrefour Brazil’s cash-and-carry unit) to facilitate that IPO. Initially, Carrefour had operated stores via Ltda. entities, but to access capital markets and expand through public investment, it needed an S.A. structure. This highlights that a company may start as an Ltda. and later spin off or convert into an S.A. for a portion of its business when going public. Another example in retail is Grupo Pão de Açúcar (GPA), a Brazilian company which foreign investors (Casino Group of France) bought into – GPA is an S.A. and publicly listed, which was necessary due to its history and size. For a foreign retailer starting fresh in Brazil (without acquiring an existing listed company), the likely path would be to set up an Ltda. subsidiary, as did Zara (Inditex) via Zara Brasil Ltda., and IKEA, which reportedly established IKEA do Brasil Ltda. for its entry. Only if and when broad ownership or stock listing becomes advantageous would they consider forming an S.A.
These examples underscore a practical trend: foreign multinationals typically favor the Ltda. form for its ease and because one parent company can wholly own it . The S.A. form appears in cases involving shared ownership, the need for significant external financing, or alignment with global corporate structures. Even then, some companies maintain the S.A. as closed capital (no public float), using it simply to structure complex ownership internally. Each sector – tech, industrial, retail – demonstrates that the decision is less about the industry and more about ownership and financing strategy. E-commerce and tech firms, often being agile and initially investment-driven by the parent, rarely need the S.A. structure early on. Industrial firms might need it if partnering with local entities or governments. Retail firms may not need S.A. unless they plan to bring in investors or public shareholders. Crucially, both Ltdas and S.A.s are capable of supporting large-scale operations in Brazil; the choice affects how the business is run rather than how much business can be done.
Strategic Recommendations for Foreign Companies
Choosing between an Ltda. and an S.A. in Brazil should be a strategic decision aligned with the company’s expansion plans:
1. Start Simple if Possible: For most foreign entrants, especially those in the e-commerce or retail space who plan to wholly own their Brazilian subsidiary, an Ltda. is the recommended starting point . It provides the necessary limited liability protection while keeping incorporation and administrative burdens low. Companies can focus on growing their market presence without the immediate need to navigate complex corporate governance requirements. Always ensure, however, that at least one reliable person (expatriate or local hire) is ready to act as the Brazil-resident administrator for the Ltda. to meet legal requirements .
2. Leverage the Flexibility of the Ltda.: An Ltda. can be adapted in many ways – you can draft the contract (Contrato Social) to include clauses often found in shareholder agreements (e.g. tag-along rights, profit distribution rules, dispute resolution mechanisms). Brazilian law allows quota holders to shape their agreement extensively. Take advantage of this by working with legal counsel to tailor the governance of your Ltda. This way, even as a simple structure, it can accommodate future needs. For instance, if you foresee possibly bringing in a minority Brazilian investor or offering a small equity stake to a local partner, you can include pre-agreed mechanisms in the Ltda.’s articles. Remember that an Ltda. can even mimic certain features of an S.A. if desired – recent changes permit Ltdas to adopt some practices of corporate law, like creating preferred quotas or classes of quotas, provided all quotaholders agree . Use this flexibility to delay or avoid a full S.A. conversion until absolutely necessary.
3. Plan for Conversion if Scaling Up: If your long-term strategy includes raising capital from Brazilian investors, issuing equity to numerous stakeholders, or going public on B3 (Brazil’s stock exchange), you will likely need to become an S.A. Identify the milestones that would trigger this conversion. It could be reaching a certain revenue or valuation, or a decision to seek an IPO or a large local loan that requires issuing debentures (which only S.A.s can do). Conversion from Ltda. to S.A. is a defined legal process – while it incurs costs and added compliance, it is straightforward in concept: the Ltda.’s quotas become shares, bylaws replace the quota contract, and governance is adjusted. Ensure that corporate approvals (from the parent company or board) for such a change are built into your expansion plan. Essentially, grow as an Ltda., but be “S.A.-ready” when the situation warrants. Many companies engage advisors to maintain their books and practices in a way that will ease the transition to S.A. (for example, by already doing audited financials and holding formal annual quotaholder meetings, even if not strictly required for the Ltda.).
4. Consider Sector-Specific Requirements: While the legal structures themselves do not change by industry, certain regulated sectors might effectively require an S.A. For example, if a foreign company in the financial services or telecomsector enters Brazil, regulators (like the Central Bank or Anatel) may expect a higher level of corporate governance, which an S.A. can fulfill more readily. Industrial and infrastructure projects that involve government tenders or concessions might also favor the S.A. form, as it can accommodate joint ventures and clear shareholding arrangements. Research if your industry has any implicit preferences. If not mandated, default to the simpler path (Ltda.), but keep an eye on industry practices.
5. Ensure Compliance and Local Expertise: Regardless of structure, adapt your company’s operations to Brazil’s legal environment early. This means engaging local accountants, lawyers, and HR consultants who are well-versed in Brazilian regulations. For an Ltda., ensure timely filing of any changes at the Junta Comercial, maintain accounting records according to Brazilian GAAP or IFRS as required, and stay on top of tax filings (monthly and annual). For an S.A., institute the more rigorous corporate routines – schedule annual general meetings within the first four months of each fiscal year to approve accounts, maintain the shareholders’ register, and so on. In either case, proactively managing compliance will avoid penalties and build a good track record with authorities. Market studies frequently warn of Brazil’s bureaucratic hurdles and the “custo Brasil”, so having experienced local staff or advisors is invaluable . Particularly with labor laws, invest in training your HR team or partner with local HR services to implement Brazilian best practices – for example, using electronic systems to track employee hours and overtime (required by law for larger companies) and providing all mandatory benefits. Adapting to these practices from day one will ease the growth of your business in Brazil and help integrate with Brazilian business culture.
6. Evaluate Tax Implications Proactively: Work with tax advisors to choose the optimal tax regime from the outset (Presumed Profit vs. Actual Profit) and revisit this choice annually. While this is not directly tied to S.A. or Ltda., it’s part of strategic planning. If your financial models show low initial profitability, Lucro Presumido could reduce tax burdens in the first years. Conversely, high-profit-margin businesses might do better under Lucro Real despite the heavier reporting, to avoid the fixed presumption rates. Additionally, if considering profit repatriation, note that dividends from both Ltdas and S.A.s are currently exempt from Brazilian withholding tax , which is a favorable policy for foreign investors. Interest on loans (including intercompany loans) will have withholding tax – some firms capitalize the subsidiary (equity) rather than lend to minimize this. These decisions intersect with corporate structure only insofar as S.A.s typically formalize these processes more (with declared dividends in AGMs, etc.). The recommendation is to integrate tax planning with your choice of entity, ensuring the chosen structure can support the most tax-efficient strategy (for example, an S.A. can more easily issue different classes of shares if there’s a need for a certain cash flow arrangement for investors, whereas an Ltda. might handle that via contractual clauses).
7. Long-Term Governance Strategy: If you foresee that an S.A. structure will be needed eventually, start instilling a governance culture early. Even as an Ltda., adopt some internal controls and practices like those of an S.A.: hold regular partner meetings, document decisions, implement approval matrices for corporate actions, and consider appointing advisory board members. This will prepare your team for the formal board structure of an S.A. when it comes. It also signals to Brazilian stakeholders (banks, partners, even regulators) that your company upholds high standards of governance, which can be beneficial for credibility. Consultancy reports often note that companies with better governance face fewer disputes and find it easier to do business in Brazil’s complex environment. So, using the flexibility of an Ltda. doesn’t mean one should be informal or lax; instead, voluntarily embracing some rigor can pay off as the business scales.
Conclusion
Choosing between a Sociedade Anônima and a Sociedade Limitada is one of the first major decisions a foreign company will make when expanding into Brazil. The Ltda. offers simplicity, privacy, and agility, making it ideal for initial market entry and for wholly owned operations in e-commerce, manufacturing, or retail . The S.A. provides a structured framework suited to larger enterprises, collaborative ventures, or companies with sights on public markets . Many successful foreign businesses in Brazil have demonstrated a pattern: start as an Ltda. to establish operations efficiently, and transition to an S.A. only if and when required by growth objectives. Both structures can succeed across Brazil’s diverse sectors – what matters is aligning the choice with the company’s capital strategy, control preferences, and compliance capabilities.
Ultimately, foreign investors should weigh the governance needs vs. administrative burden in the context of their specific industry and expansion strategy. An informed decision, backed by local legal and financial expertise, will set the foundation for sustainable growth in Brazil. By understanding the nuances outlined in this analysis – from shareholder requirements and tax regimes to real-world corporate choices – companies can enter the Brazilian market with confidence and a corporate structure optimized for their success. Brazil’s market holds great promise , and with the right strategic setup, foreign companies can unlock its potential while managing risks effectively through the appropriate corporate vehicle.
Fontes Confiáveis:
• Biz Latin Hub – “Tipos de empresas no Brasil: Qual é a mais adequada?” (artigo atualizado em 2024 com recomendações para investidores estrangeiros) .
• Domingues e Pinho Contadores – “Sócio estrangeiro em empresa no Brasil: o que considerar” (Opinião do Especialista, 2024) .
• GT Lawyers – “Joint-ventures e sociedades no Brasil” (análise jurídica comparando Ltda. e S.A. em parcerias, 2022) .
• Agilize Contabilidade – “Diferença entre LTDA e S/A: saiba qual escolher” (blog, 2024) .
• Wikipedia (pt) – “Grupo Carrefour Brasil” (histórico do IPO em 2017) ; “General Motors do Brasil” (empresa constituída como Ltda.) .
• KPMG – “Why Invest in Brazil? Legal and Tax Landscape” (guia de investimento destacando formas societárias, 2016) .
• Outreach Brasil – “Internacionalização: desafios legais e regulatórios” (artigo sobre aspectos trabalhistas e tributários em expansões, 2023) .