I’ve already filed the RDAP/RADI — what happens next?

By Alexsandro Evangelista e Adwair Guimarães

By June 30, companies holding projects benefiting from tax incentives managed by the Superintendence of the Manaus Free Trade Zone (Suframa) submitted the Project Monitoring Report (RDAP) and the Annual Import Report (RADI). As some companies have already started receiving their analysis reports, we will now discuss a bit more about the process involved.

What happens next?

According to Resolution 205/2021 and Ordinance 1398/2024, the Superintendence of the Manaus Free Trade Zone (Suframa) has a period of one year, that is, until June 30, 2025, to issue the Project Monitoring Opinion (PAP), which will consolidate the information contained in the RDAP.

During the preparation of the PAP, inspections may be carried out at the companies to verify the information provided in the RDAP. In addition, during this stage, Suframa may grant a non-extendable period of 15 days for the submission of additional information and/or accounting documents in order to confirm the stages described in the Project.

What if I receive a notification?

If the PAP suggests partial or total rejection, the company will be notified and will have up to 30 days after being informed to submit its defense. Once the defense is submitted, a new opinion will be issued within 60 days, which may be extended for an equal period. Once the defense period has expired—whether or not a defense was presented—the process will be submitted to the Deputy Superintendent for Projects for a final decision.

What if my RDAP/RADI is rejected?

If the opinion indicates rejection of the RDAP due to noncompliance with the Basic Production Process (PPB), the company must provide proof of regularization within 15 days, under penalty of blocking of the Suframa registration and suspension of Import Licensing Requests (PLI). Failure to regularize the company’s situation may result in the suspension and, ultimately, the cancellation of tax incentives.

What if it is approved?

Companies whose RDAPs are approved will be informed following deliberation by the Deputy Superintendent for Projects.