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), except companies under Simples Nacional (which file the DEFIS return instead), public agencies, and immune/exempt entities with no taxable revenue.
- 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).
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. The ECF contains specific blocks for transactions with related parties abroad (Block W) — the TP methods used, margins and amounts. 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.