ECF — Tax Accounting Bookkeeping (Escrituração Contábil Fiscal)
Mandatory annual digital filing that replaced the old DIPJ corporate income tax return. The ECF (Escrituração Contábil Fiscal) reports the assessment of IRPJ (corporate income tax) and CSLL (social contribution on net profit) — under the actual, presumed or arbitrated profit regimes — plus related-party transactions (Transfer Pricing) and the reconciliation of book profit to taxable profit (LALUR).
Filing obligation and deadline
- Who files: all legal entities subject to IRPJ (corporate income tax), including immune and exempt entities — which have their own Block U in the layout. Article 1, § 1 of Normative Instruction RFB 2,004/2021 waives only three groups: companies under Simples Nacional (which file the DEFIS return instead); public agencies, government-owned autarchies and public foundations; and dormant companies, meaning those that carried out no operational, non-operational, asset or financial activity for the whole calendar year.
- Deadline: the last business day of July of the year following the calendar year (e.g., the 2025 ECF is filed by July 31, 2026).
- Late-filing penalty: 0.25% of net profit per month of delay, capped at 10% (minimum BRL 500/month for dormant companies).
LALUR — the actual profit assessment ledger
The ECF electronically incorporates the LALUR (Livro de Apuração do Lucro Real, the actual profit assessment ledger): Part A (assessment of actual profit) and Part B (control of carry-forward balances, such as tax loss carryforwards). Book profit is adjusted by:
- Additions: non-deductible expenses (administrative fines, gifts above the legal limit, personal-use equipment).
- Exclusions: non-taxable income (dividends received), tax incentives.
- Offsets: tax loss carryforwards from prior years (limited to 30% of the current year's profit).
ECF accuracy is decisive — tax assessments frequently originate from discrepancies between the ECF, the ECD (accounting bookkeeping) and the SPED (operational digital records).
Primary sources
The ECF sits on three official layers. Decree No. 6,022 of 22 January 2007 created the Public Digital Bookkeeping System (SPED), of which the ECF is a module. The filing itself is governed by Normative Instruction RFB No. 2,004 of 18 January 2021. And the record-by-record content is set by the ECF Layout 12 Guidance Manual, annexed to Cofis Executive Declaratory Act No. 2/2026 — 621 pages that name every block, including Block U for immune and exempt entities and Block W for the Country-by-Country Report.
Frequently asked questions about the ECF
What is the difference between the ECF and the ECD?
The ECD (Escrituração Contábil Digital, Digital Accounting Bookkeeping) is the electronic version of the Journal and Ledger, replacing the physical accounting books. The ECF (Escrituração Contábil Fiscal, Tax Accounting Bookkeeping) is the assessment of IRPJ/CSLL with tax adjustments (LALUR) and specific disclosures (Transfer Pricing, related parties). The ECD is the accounting base; the ECF is the tax assessment — and they are filed on different deadlines.
Do companies under the presumed profit regime file the ECF?
Yes. The ECF is mandatory for companies under the actual, presumed and arbitrated profit regimes. The layout is simplified under the presumed profit regime (no detailed LALUR), but filing is still mandatory. Companies under Simples Nacional file the DEFIS return instead of the ECF.
What happens if the ECF is filed with errors?
Material errors can trigger a tax assessment for a divergent tax base. Corrections are made by amending the ECF (replacing the file within the legal deadline). After the deadline, an amendment is accepted only in specific cases (voluntary disclosure before an audit, with a reduced default penalty).
Does the ECF include Transfer Pricing information?
Yes, but not in Block W. Block W is the Country-by-Country Report, and none of its four records (W100, W200, W250 and W300) has a method or margin field. Transfer pricing is reported in form X370 of Block X — Economic Information, whose METODO field accepts PIC, PRL, MCL, MLT, MDL and OUT — and the margins sit in tables X375A and X375C. With Law 14.596/2023 (full OECD-aligned Transfer Pricing in force since 2024), the ECF fields were updated to reflect the new regime. Companies with international intercompany operations must complete these fields with extreme accuracy — they are a basis for international tax audits.