GLE South America

The additional US tariff on Brazilian goods is 25 per cent, effective 22 July, hitting roughly 18 per cent of Brazilian exports, about USD 7.4 billion, with aircraft and parts, beef, orange juice and energy products exempt.

Brazil’s CBS and IBS invoice fields stop being optional from 1 August, and from 3 August companies on the regular tax regime must issue documents carrying the IBS and CBS tax groups.

Colombia’s maximum ordinary working week fell to 42 hours on 15 July, and salaries, benefits, holiday entitlements and severance may not be reduced to absorb the shorter week.

A 25 Per Cent US Tariff Lands Today, and Brasília Activates the Reciprocity Law

The United States Trade Representative has imposed an additional 25 per cent tariff on most Brazilian goods effective 22 July 2026, following a Section 301 finding on digital trade, ethanol access and deforestation, with aircraft and parts, beef, orange juice and energy products exempt and roughly 18 per cent of Brazilian exports, about USD 7.4 billion, in scope. The federal government has responded by activating the Lei da Reciprocidade Económica (Lei 15.122, sanctioned 11 April 2025 and regulated by Decreto 12.551 of 14 July 2025), which allows Brazil to raise tariffs, end tariff exemptions and suspend United States intellectual-property concessions, alongside a WTO dispute filing and the 30 billion real Plano Brasil Soberano export-support credit line.

Why it matters for counsel: Map every client’s United States facing trade flow against the exempt-goods list now, and model exposure under both the 25 per cent tariff and a possible Brazilian intellectual-property suspension countermeasure. The Reciprocity Law’s ordinary procedure can run up to nine months, so early representations to Camex shape the outcome, and advisers should also flag that a separate USTR Section 301 forced-labour probe could add a further 12.5 per cent, which is forthcoming rather than in force and should not be advised on as settled.

CBS and IBS Invoice Fields Turn Mandatory on 1 August: the Test Year Stops Being Optional

Under Complementary Law 214/2025, regulated by Decreto 12.955/2026 and CGIBS Resolution 6/2026 (both published 30 April 2026), highlighting the new CBS and IBS taxes on electronic tax documents ceases to be optional and becomes a systemic requirement: the penalty-transition window under Joint Act RFB/CGIBS 1/2025 ends on 1 August 2026, and from 3 August 2026 companies on the regular tax regime must issue documents carrying the IBS and CBS tax groups. A 1 per cent test rate (0.9 per cent CBS, 0.1 per cent IBS) runs during 2026, and businesses intending to segregate calculations must notify the Receita Federal by September 2026.

Why it matters for counsel: Confirm each client’s ERP and invoicing system is parameterised to populate the IBS and CBS fields before 1 August, because invoices may otherwise be blocked or rejected. Advise on the September segregation notification and document the transition now, since 2026 is the last low-stakes year before rates ramp across 2027 to 2033.

The 42-Hour Week Landed on 15 July, and the Sunday Surcharge Rose to 90 Per Cent on 1 July

Two phased steps of Colombia’s labour reforms bit inside this fortnight: from 1 July 2026 the surcharge for work on Sundays and public holidays rose from 80 to 90 per cent under Ley 2466 de 2025, on the path to 100 per cent in July 2027, and from 15 July 2026 the maximum ordinary working week fell from 44 to 42 hours under Ley 2101 de 2021, the final step down. Salaries, social benefits, holiday entitlements and severance may not be reduced to absorb the shorter week, and public servants remain on their own separate regimes.

Why it matters for counsel: Audit clients’ shift rosters, overtime accrual and Sunday and holiday pay calculations against both changes immediately, because non-compliant payroll from July onward creates retroactive wage-claim exposure. The 90 per cent surcharge also materially changes weekend staffing economics, so employers reworking rosters need advice on the non-reduction rule before they restructure shifts.

A Mega-Deregulation Package Is Circulating in Draft, Awaiting Signature and Not Yet Law

The Ministry of Deregulation and State Transformation, led by Federico Sturzenegger, circulated a draft omnibus deregulation law in the week of 18 to 21 July 2026, running to more than one hundred articles across eight titles that would amend the Civil and Commercial Code and rewrite or repeal rules on pharmacy retail, coastal shipping, capital markets, trusts and guarantees, rural leasing, brokerage, translators and LPG pricing, including permitting cryptocurrencies as loan collateral and opening cabotage to foreign vessels. As of 21 July the text remains a pre-signature draft: it awaits President Milei’s signature, has not been sent to Congress and is not law, and press reports that an early draft sought six months of delegated legislative powers were denied by presidential sources as something that would survive into the final text.

Why it matters for counsel: Brief clients in the named sectors that a wide-ranging repeal package is imminent and prepare comment and lobbying positions now, while the text is still being settled. Do not advise on it as settled law: nothing here is in force, the specifics are subject to change before signature, and any client memo should carry that status caveat on its face.

Chile’s First Data-Protection Authority Takes Shape Ahead of the 1 December Go-Live

Ley 21.719, published 13 December 2024, overhauls Chile’s 1999 data-protection regime and creates the country’s first dedicated Agencia de Protección de Datos Personales, whose three governing-council directors take office in October 2026 ahead of substantive obligations coming into force on 1 December 2026. The law introduces full ARCO rights, a 72-hour breach-notification duty and fines of up to 20,000 UTM, rising to 4 per cent of turnover for repeat serious infringements, with SMEs facing warnings rather than fines during the first year, from December 2026 to December 2027.

Why it matters for counsel: Start clients’ gap assessments, breach-response playbooks and data-inventory work now rather than waiting for the December go-live. The 72-hour notification duty and the turnover-based fine ceiling leave no room to build compliance reactively once the Agency is operational, and the SME warning year is a grace period on penalties, not on the obligations themselves.