*Per Ary Silveira Bueno and Walter Thomaz Junior
Alongside the Tax Reform, Brazil is experiencing a significant transformation in how the tax administration interacts with taxpayers. Gradually, a logic less focused solely on auditing and enforcement and more geared towards recognizing good tax conduct, predictability, and institutional trust is being consolidated (Martini, 2022; Owens, 2023).
This change did not arise from a single regulatory act. It has been under construction for years. An important milestone in this movement was RFB Instruction No. 1,598/2015, which regulated the Program. OAS – Authorized Economic Operator. From there, a new model of relationship between the tax authorities and the taxpayer began to take shape more clearly, based on four central ideas: Compliance, Conformity, Reliability and CooperationO (Siglé et al., 2022).
These four elements — the so-called 4 Cs — help to understand the evolution of companies' tax maturity. More than isolated obligations, they represent a trajectory of institutional maturation, in which the company ceases to act only reactively to legal requirements and begins to structure its tax performance in a more organized, predictable and strategic way (OECD, 2021).
Level 1 — Compliance with the Law
The first step on this ladder is the most basic. It includes companies that maintain their basic tax compliance: regular registration with the CNPJ (Brazilian National Registry of Legal Entities), timely submission of ancillary obligations, payment of taxes due, and absence of significant tax irregularities. At this stage, the relationship with the tax authorities is still predominantly declarative and supervisory (Petzold et al., 2021).
Level 2 — Compliance: Tuning Program
The second level represents a significant advancement. Here, the taxpayer is systematically evaluated regarding the quality of their tax behavior. This is the space of... Sintonia Program, created by RFB Ordinance No. 511/2025 and subsequently elevated to the status of public policy by LC 225/2026.
Through it, the Federal Revenue Service classifies taxpayers according to their degree of compliance, in categories such as A+, A, B, C, and D. In practice, Sintonia introduces something close to a... rating fiscal, allowing companies to be distinguished not only by their tax payments, but also by the consistency and reliability of their information (Russo et al., 2022).
The classification considers four main areas: registration, declarations and accounting records, consistency of information provided, and payment of taxes. Good classification is not a matter of chance—it is the result of well-designed processes, consistent routines, data review, operational discipline, and technical training (Bello-Pérez, 2022).
Level 3 — Reliability: Authorized Economic Operator (AEO)
For companies operating in foreign trade, the maturity ladder advances to a third level: that of operational reliability, materialized through certification. OAS.
O OAS It is more than a seal. It represents Customs' recognition that the company operates with a high degree of reliability in its customs and logistics routines. Among the criteria evaluated are: traceability of operations, tax and customs compliance, internal controls, risk management, and supply chain security (Martini, 2022).
The company certified as OAS It will now receive preferential treatment in foreign trade operations, with significant gains in agility, predictability, and institutional recognition.
Level 4 — Cooperation: CONFIA Program
At the top of this ladder is the most sophisticated level: that of cooperation, represented by CONFIA Program – Cooperative Tax Compliance, established by LC 225/2026 and, at least for now, aimed at a more restricted group of large companies.
O TRUST It is not limited to examining fiscal regularity, compliance history, or operational security. It looks at something deeper: the organization's tax governance (Folloni et al., 2024). International literature characterizes this model as an evolution from punitive regimes to partnerships based on trust and transparency, in which there is an advance exchange of information, internal control structures, and mutual guarantees to reduce disputes and increase legal certainty (Calijuri & Oliveira, 2023; Ribes, 2022).
Among the relevant aspects of this model are: internal controls for fiscal risk, institutional maturity of compliance, transparency in the relationship with the Federal Revenue Service, fiscal regularity, and the existence of a structured tax compliance management system. At this stage, the relationship between taxpayer and tax authorities tends to cease being merely corrective or repressive, becoming more preventive, technical, and cooperative (Owens, 2023).
The Evolutionary Logic of Tax Compliance
When we observe the Sintonia, OEA, and CONFIA programs together, we realize that they are not isolated initiatives. On the contrary, they form a coherent path of institutional maturation:
Compliance → Conformity → Reliability → Cooperation
This sequence reveals an important shift in the paradigm of Brazilian tax administration, aligned with international best practices. OECD. The focus is no longer exclusively on punishing non-compliance, but also includes recognizing, valuing, and encouraging good taxpayers (OECD, 2021; Siglé et al., 2022).
Compliance as a Management Tool
More than just following a trend associated with ESG, the implementation of a compliance program needs to be understood as a... management tool. Effective compliance is not just about reputational rhetoric, nor is it a set of formal policies designed "for show.".
Its real value lies in supporting the company in organizing processes, identifying and addressing risks, defining controls, and continuously training the people involved (Martini, 2022; Bello-Pérez, 2022).
In other words, serious tax compliance is not just about image: it's about method, management discipline, and business protection. Companies that climb this ladder of maturity build not only greater legal security, but also institutional credibility, operational predictability, and a better position with the tax authorities and their stakeholders (Petzold et al., 2021).
Conclusion
The coexistence of the programs Harmony, OAS and CONFIA This shows that Brazil is moving, in an increasingly clear way, towards a model aligned with international best practices in cooperative compliance. In this environment, tax compliance ceases to be merely a legal obligation and becomes a strategic intangible asset.
To climb each of these steps — from Compliance with Cooperation Having access to specialized technical support can make all the difference.
To see the references used in the article, visit: https://www.linkedin.com/pulse/os-4-cs-na-escada-de-maturidade-da-conformidade-xsx7f/?trackingId=sCfG8q2cTJmKeuXAWCwApQ%3D%3
*Ary Silveira Bueno, Managing Partner of ASPR
Walter Thomaz Junior, Managing Partner of Portorium
Notice: The opinion expressed in this article is the responsibility of its authors and not of ABES – Brazilian Association of Software Companies
