Espírito Santo Creates Logistics Hubs to Attract Major Companies

On 4 May 2026, the Governor of the State of Espírito Santo enacted Decree No. 6,394-R ("Decree 6,394"), officially creating Parklog Sul Capixaba ("Parklog South"), a strategic state government program designed to transform southern Espírito Santo into one of the most ambitious logistics ecosystems in Brazil. With projected investments of BRL 25 billion and the capacity to handle 266 million tons per year, the project places the region on Brazil's logistics and foreign trade map.

Previously, in 2024, State Decree No. 5,831-R ("Decree 5,831") had already established Parklog Norte Capixaba ("Parklog North"), with more than BRL 12 billion in projected investments, encompassing 10 municipalities along the state's northern coastline.

What is Parklog?

Parklog is the Espírito Santo State Government's platform for integrating, under a single public coordination structure, the main logistics assets of a region, including ports, railways, highways, airports, and industrial areas. The model does not create infrastructure from scratch; rather, it organizes existing assets, sends a clear signal to the market, and enhances available incentives in order to attract private investment.

The New Parklog South

Southern Espírito Santo accounts for 94.6% of Brazil's ornamental stone exports, and is expected to receive more than BRL 19 billion in oil royalties by 2056. These are resources and assets that, at present, are still not operating at their full potential, which Parklog South seeks to change.

The pillars of the new Parklog South ecosystem are:

• Porto Central, in Presidente Kennedy, a superport currently under construction, with approximately BRL 2.6 billion in first-phase investments and operations expected to begin in 2028;
• The Port of Ubu, in Anchieta, operated in connection with Samarco's activities and currently under negotiations for its conversion into a multipurpose terminal for general cargo;
• The EF-118 Railway, a 575-kilometer rail line connecting southern Espírito Santo to Rio de Janeiro (known as the Southeast Railway Ring), with its concession auction expected in December 2026 and investments estimated at BRL 7.7 billion; and
• Cachoeiro de Itapemirim Airport, upgraded through BRL 76.5 million in state investments; and offshore wind energy potential, among other assets.

It is worth noting that, although Decree 6,394 formally launched the program, the relevant technical studies are still under development. The definitive territorial boundaries and the legal framework governing the southern Espírito Santo Export Processing Zone (ZPE), for example, have yet to be disclosed. We will continue monitoring developments in order to identify opportunities for real estate development, project structuring, and access to the initial incentives that may be established under the program.

Parklog North and the Consolidation of the Project

By contrast, Parklog North is already at a more advanced stage and offers a robust package of federal and state incentives, supported by operational assets and a consolidated legal framework.

The pillars of the Parklog North ecosystem are:

• The private ports of Portocel, Imetame, and Vports, located in Aracruz and Barra do Riacho, which form the port core of the complex with established operations;
• The Vitória-Minas Railway (EFVM), with a branch line to Aracruz and the prospect of expansion through the Central-East Corridor;
• The Aracruz Export Processing Zone (ZPE), under private management and established by Federal Decree No. 11,735/2023 ("Federal Decree 11,735"); and
• The aerodromes of Aracruz and Linhares, supporting executive and cargo air logistics; and the industrial clusters and dry ports distributed across the municipalities covered by the program, including Colatina, João Neiva, Serra, and Linhares.

A recent highlight is the announcement of Great Wall Motor’s project to build a new manufacturing facility in Brazil on a 1.7 million-square-meter site near Portocel, with investments estimated at BRL 4.6 billion. Operations are expected to begin in 2029.

From a tax perspective, one advantage of northern Espírito Santo is that the region allows the combination of federal incentives (SUDENE and ZPE) and state incentives (INVEST-ES and COMPETE-ES), as detailed in the section Tax Incentives and Location Decisions below.

Tax Incentives Applicable to Projects in the Parklog North Region

Northern Espírito Santo allows investors to combine three different incentive mechanisms.

• SUDENE: Corporate income tax reduction. Part of the municipalities covered by Parklog North falls within SUDENE's area of operation (Complementary Law No. 125/2007, as amended by Complementary Law No. 185/2021), allowing projects classified within priority sectors to benefit from a reduction in Corporate Income Tax (IRPJ) calculated on profits derived from the incentivized activity for a 10-year period (Provisional Measure No. 2,199-14/2001; Decree No. 9,682/2019). The legislation provides for a reduction of up to 75% of IRPJ for installation, expansion, modernization, or diversification projects, as well as the possibility of reinvesting up to 30% of the tax due in modernization projects and complementary equipment investments (Law No. 8,167/1991, Article 19). Projects must be filed and approved by December 31, 2028 (Law No. 13,799/2019). However, Complementary Law No. 224/2025 introduced a flat 10% reduction in federal tax incentives. As a result, for projects subject to Complementary Law No. 224/2025, the IRPJ reduction will be 67.5%, and the reinvestment percentage will decrease from 30% to up to 27%.

• ZPE: Tax relief on CAPEX for export-oriented projects. The Export Processing Zone (ZPE) regime (Law No. 11,508/2007, as amended by Law No. 14,184/2021) was preserved under Brazil's Tax Reform, and is subject to specific treatment under the IBS and CBS systems (Complementary Law No. 214/2025). For companies authorized to operate within ZPEs, the regime reduces the tax burden associated with the importation of machinery, equipment, inputs, and certain services connected to export-oriented activities. The impact extends both to ongoing operational taxation and to implementation costs. The ZPE regime also provides a specific foreign exchange framework, allowing export proceeds to remain abroad, and offers more streamlined customs and administrative procedures.

• INVEST-ES and COMPETE-ES: State ICMS incentives. The State offers two incentive programs: INVEST-ES (State Law No. 10,550/2016), aimed at new ventures and expansions, and COMPETE-ES (State Law No. 10,568/2016), focused on enhancing the competitiveness of industries already established in the State. The available mechanisms include ICMS deferrals, reductions in the tax base, and deemed tax credits. Examples include ICMS deferrals on imported capital goods for industrial projects or deemed tax credits on interstate sales of products manufactured within the State. Eligibility depends on the project's classification, economic sector, and the terms of the applicable granting act.

As a general rule, the competitive advantage does not derive from a single benefit. Rather, it lies in the combination of SUDENE, ZPE, state incentive programs, and logistics infrastructure. Location decisions require an assessment of revenue profiles, CAPEX intensity, foreign exchange exposure, implementation schedules, and project maturity horizons. Timing also matters. A project structured today will pass through different stages of Brazil's tax transition, including the progressive reduction of ICMS incentives and the implementation of IBS and CBS.

Tax Insights | What Will Happen to Tax Incentives Under Brazil's Consumption Tax Reform?

Brazil's Tax Reform gradually changes the traditional model of tax competition among states. Between 2029 and 2032, ICMS rates will be reduced annually to 90%, 80%, 70%, and 60%, respectively, of the rates currently in effect, until the tax is fully extinguished in 2033 (Constitutional Amendment No. 132/2023, ADCT, Article 125 et seq.). Tax or financial incentives related to ICMS that are not automatically reduced as a consequence of the rate reduction itself will also be proportionally reduced according to the constitutional transition schedule. In Espírito Santo, this transition will affect, among others, benefits associated with INVEST-ES and COMPETE-ES.

The constitutional framework governing the IBS restricts the granting of tax incentives. Nevertheless, states will continue to have instruments available to attract investment, particularly through financial and credit subsidies. The Tax Reform itself created the National Regional Development Fund (Constitutional Amendment No. 132/2023, ADCT, Article 159-A), whose resources may be used by states for infrastructure projects, scientific and technological development, and support for productive activities. Financing, infrastructure support, and development policies will therefore become increasingly important factors in the competition to attract new projects.

For long-term investments, location decisions will involve not only infrastructure and logistics considerations, but also an assessment of which states will have greater legal flexibility to grant subsidies under the new constitutional framework. More than identifying incentives currently available, investors will need to evaluate where to locate, when to invest, and how to structure their operations to capture value throughout the entire lifecycle of the project.

How We Can Help

Tauil & Chequer Advogados in association with Mayer Brown brings together multidisciplinary capabilities in tax, regulatory, energy, infrastructure (including ports, railways, and highways), corporate, and mergers and acquisitions matters, supported by a local presence in Espírito Santo. In the tax field, we assist clients from tax feasibility analyses and incentive structuring (including SUDENE, ZPE, REIDI, INVEST-ES, and COMPETE-ES) through the operational implementation of projects, including registrations before competent authorities, negotiation of incentive agreements, and planning for the transition to Brazil's new tax framework.

For investors evaluating opportunities within Parklog, the regulatory developments expected over the coming months will be decisive and require legal counsel capable of closely monitoring legislative and regulatory developments at both the federal and state levels.

This material is provided for informational purposes only and does not constitute a legal opinion or legal advice. The information contained herein reflects the legislation in force as of the date of publication and may be amended without prior notice.