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Is there any specific legislation that determines that contingent workers should be treated as employees for (a) employment, (b) tax/social security or (c) pension purposes?

(a) No, except in case of employment misclassification.

(b) No, the social security and income tax legislation sets out the specific rules applicable to contingent workers.

(c) Same as (b).

Is there a safe harbor for contingent workers for (a) employment, (b) tax/social security or (c) pension purposes? Safe harbor means being expressly excluded from the legislation or a particular category/classification under the legislation if certain conditions are met.

(a) No. As a rule, substance prevails over form for labor matters in Brazil. If employment elements are present, contingent workers could be considered as employees for employment purposes.

(b) If the requirements of an employment relationship are not present, the social security and income tax legislation sets out the specific rules applicable to contingent workers.

(c) Same as (b).

Are there any new developments coming up in relation to contingent workers? If so, please briefly describe them along with the timing.

The issue of platform workers' labor rights is currently under discussion in Brazil, mainly considering the proposed agenda of the newly elected government. With the rise in digital platform services, we are seeing an increasing global trend in case law and legislation aimed at protecting platform workers' labor rights. For more insight on these developments, along with other employment law updates, click here.

What are the main risks of engaging contingent workers from an employment law perspective?
4 - High risk

The main risks are misclassification of workers and related consequences (i.e., individual and class actions).

Consequences of violation – employment law perspective

On average, penalties are approximately BRL 3,000 per offense or per individual who should be registered as an employee. This does not include the retroactive payment of wages, benefits and taxes, plus monetary adjustment/interest.

What are the main risks of engaging contingent workers from a tax perspective?
2 - Low risk

The following are the main risks from a tax perspective: • There is a risk of contingent workers being reclassified as employees, leading to a tax assessment claiming the payment of social security contributions upon compensation. • There is no issue related to income tax, because the withholding tax rates are the same for contingent workers and employees.

Consequences of violation – tax perspective

For a tax assessment that considers the contingent workers as employees, the authorities may claim the payment of social security contributions and a 75% penalty upon the contributions due.

What are the main risks of engaging contingent workers from a social security perspective?
3 - Moderate risk

For a tax assessment that considers the contingent workers as employees, the authorities may claim the payment of social security contributions.

Consequences of violation – social security perspective

There would be a penalty of 75% of the contributions due. If the tax authorities consider that the contingent worker was only hired to avoid the contributions due on the employee's compensation, via the use of fraud or simulation, the administrators (finance, accounting or human resources) may be considered as jointly liable.

What are the main risks of engaging contingent workers from a pensions (or other regulator) perspective?
2 - Low risk

There is no mandatory private pension in Brazil, meaning the hiring of contingent workers may not lead to pension-related risks.

Consequences of violation - pensions (or other regulator) perspective

N/A

Are there any wider tax compliance risks, e.g., senior accounting officer or corporate criminal offense of facilitating tax evasion?

Yes, if the tax authorities consider that the contingent worker was only hired to avoid the contributions due on the employee's compensation, via the use of fraud or simulation, the administrators (finance, accounting or human resources) may be considered as jointly liable.

What is the risk of criminal sanctions applying?

The risk is low.

Overall risk rating
3 - Moderate risk

This is a combined risk rating across all areas, including likelihood of challenge, impact of challenge and uncertainty of law.