R&D&I PLAN: DEADLINE (MAY 31)
- Nathália Gabriel

- May 22, 2025
- 2 min read
Updated: Oct 10, 2025
By Nathália Gabriel and Sarah Benezar, from the R&D&I team.

Companies seeking to benefit from the tax incentives of the Manaus Free Trade Zone (ZFM) must pay close attention to the Research, Development and Innovation (R&D&I) Plan. This formal document is essential for the organization and implementation of innovation projects and actions, and it is a mandatory requirement for maintaining the tax benefits granted in the region.
The preparation and submission of the R&D&I Plan are regulated by Joint Ordinance ME/SUFRAMA No. 9,835/2022, which establishes the guidelines and deadlines for its presentation and approval.
When must the Plan be submitted?
According to §§5 and 2 of Article 14 of Ordinance No. 9,835, the plan must be submitted by May 31 of the year preceding the start of the activities described in it, covering the investments for two base years.
Failure to submit or incorrect submission
Failure to submit, or the incorrect submission of, the R&D&I Plan may lead to penalties for companies benefiting from the fiscal incentives administered by SUFRAMA, as provided for in current legislation:
JOINT ORDINANCE ME/SUFRAMA No. 9,835/2022
Art. 27. Failure to submit the R&D&I Plan, or submission not in compliance with the requirements established in this Joint Ordinance, may result in the penalties provided for in Article 34 of Decree No. 10,521/2020.
DECREE No. 10,521/2020 – Chapter X – Penalties
Art. 34. In the event of non-compliance with the requirements established in this Decree, or rejection of the reports referred to in Article 30, the granting of the benefit will be suspended, without prejudice to the reimbursement of previously enjoyed benefits, duly updated and subject to applicable fines on tax debts of the same nature.
To ensure full compliance with legal requirements and avoid setbacks in the plan’s approval, specialized advisory support can make all the difference.
With over 29 years of experience in the Manaus Free Trade Zone, DD&L Consultores is ready to assist your company throughout this process, ensuring that all regulatory guidelines are properly met.
Get in touch and learn how we can help!




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