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2026 Statistics

Key Facts: SEFAZ-MG Auditor Fiscal Exam

130 Questions

Total objective multiple-choice test questions (P1: 50, P2: 80)

SEF-MG / FGV Official Notice

8 Hours

Total examination duration (Morning and Afternoon sessions)

Secretaria de Estado de Fazenda de Minas Gerais

R$ 183,50

Candidate exam registration fee

SEF-MG Official Competition Notice

60% Overall

Minimum aggregate passing score (with 50% min per paper)

FGV Examination Board Rules

Nível Superior

Mandatory higher education bachelor credential

Governo do Estado de Minas Gerais

SEFAZ-MG Auditor Fiscal da Receita Estadual tests Minas Gerais tax statutes (Lei 6.763/1975, Novo RICMS-MG Decreto 48.589/2023, CCMG RPTA), national tax law, advanced accounting, SPED fiscal auditing, and legal disciplines. This bank provides 100 high-yield practice MCQs with in-depth pedagogical explanations.

Sample SEFAZ-MG Auditor Fiscal Practice Questions

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1Under Minas Gerais State Law No. 6.763/1975 and the New ICMS Regulation (Decreto nº 48.589/2023), at what precise moment is the fato gerador (taxable event) of ICMS deemed to occur in a commercial operation involving the sale of industrial merchandise from a factory located in Contagem/MG?
A.At the moment of the physical exit (saída) of the merchandise from the commercial or industrial establishment of the taxpayer.
B.At the moment the sales contract is signed and registered before the Junta Comercial do Estado de Minas Gerais (JUCEMG).
C.At the moment the financial payment is credited to the seller's commercial bank account via PIX or bank transfer.
D.At the moment the electronic invoice (NF-e) is authorized by the SEF-MG tax server, regardless of physical dispatch.
Explanation: Pursuant to Art. 5, I of Minas Gerais State Law No. 6.763/1975 and the Novo RICMS-MG (Decreto nº 48.589/2023), the fato gerador of ICMS occurs at the moment of the physical departure (saída) of the merchandise from the taxpayer's establishment. Under Brazilian tax law, civil contract formalization, invoicing, or financial settlement do not replace the physical dispatch as the statutory trigger for the tax obligation.
2A textile manufacturer headquartered in Juiz de Fora/MG transfers raw materials to its industrial branch located in Uberlândia/MG without transferring legal ownership. In light of STF Declaratory Action of Constitutionality No. 49 (ADC 49), Complementary Law No. 204/2023, and Minas Gerais State Law No. 6.763/1975, how is this internal movement treated for ICMS purposes?
A.The transaction is fully taxable at the standard 18% internal rate, because any physical movement of inventory across municipal boundaries generates ICMS debt.
B.The physical transfer between establishments of the same legal owner is characterized by constitutional non-incidence (não-incidência) of ICMS, and the taxpayer maintains the right to transfer accrued input tax credits.
C.The transfer is considered an exempt operation (isenção) that strictly obligates the taxpayer to reverse (estornar) all previously appropriated input credits.
D.The operation is subject to ICMS Substituição Tributária (ICMS-ST), requiring the dispatching establishment to withhold tax based on presumed resale value.
Explanation: Following STF binding jurisprudence in ADC 49 and the enactment of Complementary Law No. 204/2023 (incorporated into MG tax statutes), the mere physical transfer of goods between establishments belonging to the same legal entity is not a taxable event (não-incidência). Furthermore, LC 204/2023 explicitly guarantees that non-incidence does not impede the maintenance and transfer of accumulated input tax credits to the destination establishment.
3A supermarket chain in Belo Horizonte/MG acquires food staples belonging to the basic food basket (cesta básica) with an internal ICMS tax base reduction of 50%. The acquisition occurred with regular ICMS credit taxation. Under Lei Estadual nº 6.763/1975 and Decreto nº 48.589/2023 (Novo RICMS-MG), what rule applies to the input tax credit appropriation in this scenario?
A.The taxpayer is prohibited from taking any input credit whatsoever on operations that benefit from a partial tax base reduction.
B.The taxpayer may fully retain 100% of the input credit regardless of any specific statutory authorization, because base reductions do not equate to exemptions.
C.The taxpayer must effect a proportional credit reversal (estorno proporcional de crédito) of 50% of the input tax credit, unless state legislation expressly authorizes credit maintenance (manutenção de crédito).
D.The taxpayer must pay a compensatory state fee (Taxa de Expediente) equal to the value of the tax base reduction before utilizing the input credit.
Explanation: Under Art. 155, §2º, II, 'b' of the Federal Constitution and Art. 32 of Lei Estadual nº 6.763/1975, a reduction in the calculation base is legally equivalent to a partial tax exemption, which requires a proportional reversal (estorno) of the input tax credit. However, when the state tax law or CONFAZ agreement expressly provides for credit maintenance (manutenção de crédito), the full credit may be preserved.
4An auto parts manufacturer in Betim/MG sells spare parts to an end-consumer in Belo Horizonte/MG for R$ 100,000.00. The commercial invoice includes R$ 5,000.00 of freight charged to the buyer, R$ 2,000.00 in insurance, an unconditional trade discount (desconto incondicional) of R$ 7,000.00, and IPI at 10% (R$ 10,000.00). According to Lei Estadual nº 6.763/1975 and CF/88 Art. 155, §2º, XI, what is the ICMS calculation base (base de cálculo)?
A.R$ 100,000.00, because IPI is always excluded from the ICMS tax base under constitutional non-cumulativity.
B.R$ 107,000.00, because unconditional discounts are added back to the gross tax base under Minas Gerais tax regulations.
C.R$ 93,000.00, because freight, insurance, and IPI must all be deducted from retail consumer transactions.
D.R$ 110,000.00, because IPI is included in the ICMS tax base when the sale is made directly to an end-consumer.
Explanation: Under CF/88 Art. 155, §2º, XI and Lei Estadual nº 6.763/1975 Art. 13, IPI is excluded from the ICMS base ONLY when the transaction is between taxpayers AND involves products intended for industrialization or commercialization. When selling to an end-consumer, IPI is included in the ICMS base. Calculation: Merchandise (R$ 100,000) + Freight (R$ 5,000) + Insurance (R$ 2,000) - Unconditional Discount (R$ 7,000) + IPI (R$ 10,000) = R$ 110,000.00.
5In the State of Minas Gerais, Lei Estadual nº 6.763/1975 establishes specific internal ICMS tax rates and institutes an additional rate to finance the Fundo de Erradicação da Miséria (FEM). How does the FEM surcharge apply to internal retail sales of superfluous goods such as alcoholic beverages, perfumes, and firearms?
A.An additional surcharge of 2% is added to the standard or specific internal ICMS rate, raising the effective state tax burden on designated superfluous goods.
B.A flat surcharge of 5% is levied as a separate municipal excise tax collected via a municipal DAM document.
C.The FEM surcharge of 2% is deducted directly from the gross receipts as a tax credit rather than added to the final ICMS rate.
D.The FEM surcharge applies exclusively to interstate wholesale outbound transactions originating from Minas Gerais to other federation units.
Explanation: Pursuant to Art. 12-A of Lei Estadual nº 6.763/1975 and complementary state legislation, an additional rate of up to two percentage points (2%) is levied on internal operations with specific superfluous consumer goods (such as beer, cigarettes, perfumes, weapons, and luxury cosmetics) to fund the Fundo de Erradicação da Miséria (FEM). This surcharge is collected alongside the state ICMS.
6A commercial distributor in Pouso Alegre/MG ships imported consumer electronics (which have an imported content greater than 40% and no national equivalent list exemption) to a corporate taxpayer located in Recife/PE. What is the applicable interstate ICMS tax rate for this outbound transaction from Minas Gerais?
A.7%, which is the standard interstate tax rate applied from Southeast states to the Northeast region of Brazil.
B.4%, pursuant to Federal Senate Resolution No. 13/2012 (Resolução do Senado Federal nº 13/2012) for imported goods.
C.12%, because all interstate commercial transactions in Brazil are uniformly taxed at 12% under Lei Kandir.
D.18%, because the goods are imported and must bear the full internal rate of Minas Gerais upon interstate departure.
Explanation: Under Federal Senate Resolution No. 13/2012, interstate operations involving imported foreign goods or goods with an Import Content (Conteúdo de Importação - CI) exceeding 40% are subject to a uniform interstate ICMS rate of 4%, overriding the general regional 7% or 12% interstate rates.
7An industrial taxpayer in Sete Lagoas/MG acquires a specialized manufacturing machine for its permanent fixed assets (ativo imobilizado) on January 10, generating an ICMS input credit on the invoice of R$ 96,000.00. In January, the company's total sales revenue is R$ 1,000,000.00, consisting of R$ 750,000.00 in fully taxable and export sales, and R$ 250,000.00 in tax-exempt sales without credit maintenance. Under Lei Estadual nº 6.763/1975 and the Novo RICMS-MG (CIAP calculation), what is the allowable ICMS credit for January?
A.R$ 2,000.00, because fixed asset credits are appropriated uniformly at 1/48th of the total invoice tax without applying output revenue ratios.
B.R$ 96,000.00, because fixed assets allow immediate full single-installment credit appropriation in the month of entry.
C.R$ 1,500.00, calculated as (R$ 96,000 / 48) multiplied by the taxable output ratio of 75% (R$ 750,000 / R$ 1,000,000).
D.R$ 72,000.00, calculated by multiplying the full tax credit (R$ 96,000) by the 75% taxable ratio in a single upfront lump sum.
Explanation: Pursuant to LC 87/1996 and Minas Gerais tax rules (Decreto nº 48.589/2023 - CIAP), fixed asset ICMS credits are appropriated monthly at 1/48th of the total credit, multiplied by the ratio of taxable/export operations to total operations in that month. Monthly fraction = R$ 96,000 / 48 = R$ 2,000.00. Taxable ratio = R$ 750,000 / R$ 1,000,000 = 0.75 (75%). Allowable credit for January = R$ 2,000.00 × 0.75 = R$ 1,500.00.
8A commercial retail department store in Montes Claros/MG receives an electric utility bill totaling R$ 50,000.00 with ICMS highlighted at R$ 9,000.00. Under Lei Complementar nº 87/1996 (Lei Kandir) and Minas Gerais tax regulations (Decreto nº 48.589/2023), how is the ICMS credit on this electricity bill treated?
A.The full R$ 9,000.00 may be credited immediately, as all corporate electricity bills generate non-cumulative tax credits.
B.A standard 50% deemed credit (crédito presumido) of R$ 4,500.00 may be appropriated under general administrative overhead rules.
C.The credit is permitted only if the commercial establishment operates its own backup diesel generator.
D.The input ICMS credit cannot be appropriated by the commercial establishment, as electrical energy credits are legally restricted to consumption in industrial manufacturing processes, energy commercialization, or export operations.
Explanation: Under Art. 33, II of LC 87/1996 and Art. 28 of Lei Estadual nº 6.763/1975, input ICMS credits on electric energy consumption are strictly conditioned until future statutory unlock dates: they are only creditable when consumed directly in an industrialization process, when the electricity itself is the object of commercialization/supply, or in proportion to export sales. Pure commercial and retail establishments cannot credit ICMS on electric power.
9A food processing plant in Varginha/MG suffers a warehouse fire that completely destroys raw materials valued at R$ 300,000.00, for which R$ 36,000.00 in ICMS input credits had been legitimately appropriated upon purchase. Under Lei Estadual nº 6.763/1975 and the Novo RICMS-MG, what is the taxpayer's legal obligation regarding the previously appropriated ICMS credit?
A.The taxpayer must effect an administrative reversal (estorno de crédito) of the full R$ 36,000.00 in its fiscal ledger (EFD ICMS/IPI), as the merchandise deteriorated or was destroyed prior to a taxable departure.
B.The taxpayer may retain the credit in full, because casualty losses (caso fortuito ou força maior) automatically preserve input tax credits.
C.The taxpayer must pay a punitive fine of 100% of the credit value within 24 hours of the fire incident.
D.The taxpayer may convert the destroyed stock into a tax credit against municipal property taxes (IPTU).
Explanation: Under Art. 32, III of Lei Estadual nº 6.763/1975 and the Novo RICMS-MG (Decreto nº 48.589/2023), the taxpayer must reverse (estornar) the ICMS credit previously appropriated whenever merchandise acquired for commercialization or industrialization is lost, deteriorated, stolen, destroyed, or consumed in an uninsurable casualty.
10A manufacturer in São Paulo/SP sells goods subject to ICMS-ST to a retailer in Belo Horizonte/MG for R$ 10,000.00. The original MVA (MVA original) defined in the CONFAZ agreement is 40%. The interstate tax rate from SP to MG is 12%, and the internal tax rate in MG is 18%. Using the official MVA Ajustada formula: MVA Ajustada = [((1 + MVA original) * (1 - ALQ inter)) / (1 - ALQ intra)] - 1, what is the MVA Ajustada to be applied to determine the ICMS-ST calculation base?
A.40.00%
B.50.24%
C.34.15%
D.62.50%
Explanation: Applying the official MVA Ajustada formula: MVA Ajustada = [((1 + 0.40) * (1 - 0.12)) / (1 - 0.18)] - 1 = [(1.40 * 0.88) / 0.82] - 1 = [1.232 / 0.82] - 1 = 1.502439 - 1 = 50.24%. This ensures that the tax burden on interstate acquisitions equals the tax burden that would arise if the transaction were executed entirely internally in Minas Gerais.

About the SEFAZ-MG Auditor Fiscal Exam

The Concurso Público para Auditor Fiscal da Receita Estadual da Secretaria de Estado de Fazenda de Minas Gerais (SEFAZ-MG) is among the most prestigious subnational fiscal careers in Brazil. Operating in Brazil's second most populous state and third largest state economy, Auditors Fiscal hold constitutional authority to supervise and inspect corporate taxpayers, audit commercial and industrial operations, constitute state tax credits (ICMS, IPVA, ITCD, and Taxas Estaduais) via formal Auto de Infração, audit electronic bookkeeping and invoicing (SPED Fiscal, ECD, ECF, NF-e, CT-e, MDF-e), investigate sophisticated corporate tax evasion, and participate in administrative litigation at the Conselho de Contribuintes do Estado de Minas Gerais (CCMG). The examination rigorously tests state tax statutes (Lei Estadual nº 6.763/1975, Novo Regulamento do ICMS Decreto nº 48.589/2023, IPVA Lei nº 14.937/2003, ITCD Lei nº 14.941/2003, Taxas Estaduais, and RPTA Decreto nº 44.747/2008), the National Tax System (CF/88 Arts. 145–162 and CTN Lei nº 5.172/1966), CPC/IFRS corporate accounting, tax auditing techniques, administrative law (Lei nº 14.133/2021 and MG statutory regimes), and quantitative analysis.

Assessment

Prova I — Conhecimentos Gerais (80 questions: Língua Portuguesa, Raciocínio Lógico-Matemático, Direito Administrativo, Direito Constitucional e Direitos Humanos, Direito Civil e Empresarial, Direito Penal, Direito Tributário, Contabilidade Geral, Economia e Matemática Financeira); Prova II — Conhecimentos Específicos (50 questions, weighted 2 points each, varying by the chosen Área de Conhecimento); Prova III — written discursive paper with 4 questions of up to 30 lines each.

Time Limit

Prova I 4h30 and Prova II 3h30 on the same day (morning and afternoon shifts); Prova III 4h30 on a separate date

Passing Score

No zero in any discipline of Provas I and II, plus at least 32 of 80 correct in Conhecimentos Gerais and 25 of 50 in Conhecimentos Específicos

Exam Fee

R$ 183,50 (Secretaria de Estado de Fazenda de Minas Gerais (SEF-MG), examination organised by Fundação Getulio Vargas (FGV))

SEFAZ-MG Auditor Fiscal Exam Content Outline

30%

Legislação Tributária do Estado de Minas Gerais

Minas Gerais State Tax Code (Lei Estadual nº 6.763/1975); New ICMS Regulation (Novo RICMS-MG Decreto nº 48.589/2023 / Decreto nº 43.080/2002): taxable events, constitutional non-incidence, statutory exemptions, calculation bases, standard and specific tax rates, FEM (Fundo de Erradicação da Miséria), tax credit rules, reversals, CIAP (1/48 appropriation), and electronic special tax regimes (e-PTA); Tax Substitution (ICMS-ST), Margem de Valor Agregado (MVA and adjusted MVA formulas), tax restitution and reimbursement (Tema 201 STF / Art. 22 RICMS-MG); Interstate Rate Differential (DIFAL under EC 87/2015 and LC 190/2022); IPVA (Lei Estadual nº 14.937/2003); ITCD (Lei Estadual nº 14.941/2003); State Fees (Taxas Estaduais: TRLAV, Taxa de Segurança Pública, Taxa de Expediente); and Administrative Tax Process (RPTA Decreto nº 44.747/2008, Auto de Infração, defenses, and Conselho de Contribuintes do Estado de Minas Gerais - CCMG).

25%

Direito Tributário Constitucional e Código Tributário Nacional (CTN)

National Tax System in CF/88 (Arts. 145–162): constitutional principles (legality, anteriority, non-confiscation, capacity to pay, non-discrimination), constitutional immunities (reciprocal, religious, education/social assistance, press/books, musical recordings, export immunity); National Tax Code (CTN Lei nº 5.172/1966): tax obligations, taxable events, active and passive capacity, tax liability (successors, third parties Art. 134, corporate managers Art. 135), tax credit constitution and assessment modalities (lançamento de ofício, por declaração, por homologação; decadence rules under Arts. 150 §4º and 173), suspension of tax credit (Art. 151), extinction of tax credit (Art. 156: payment, compensation, remission, decadence, prescription Art. 174, dation in payment), exclusion (Art. 175: exemption, amnesty), tax guarantees and privileges, active debt registry (Dívida Ativa), and tax clearance certificates (CND/CPEN); Supplementary tax legislation (Lei Kandir LC nº 87/1996, Simples Nacional LC nº 123/2006 with MG state sublimits, CONFAZ LC nº 24/1975, and LC nº 160/2017 fiscal war convalidation).

25%

Contabilidade Geral, Avançada, Custos e Auditoria Fiscal / SPED

Brazilian Accounting Pronouncements (NBC TG / CPCs): Conceptual Framework (CPC 00 R2), Inventories (CPC 16: cost formula, net realizable value, recoverable tax exclusion), Property Plant and Equipment (CPC 27: initial recognition, depreciation methods, residual value, impairment CPC 01), Provisions and Contingencies (CPC 25: probable, possible, remote obligations), Equity Method (CPC 18: MEP, goodwill, unrealized intercompany profits), Consolidated Financial Statements (CPC 36); Cost accounting: absorption costing vs variable costing, contribution margin, breakeven points; Tax auditing techniques, substantive testing, analytical procedures, audit sampling (NBC TA 530), audit opinions; SPED Fiscal (EFD ICMS/IPI: Bloco 0, Bloco C, Bloco D, Bloco E, Bloco G, Bloco H, Bloco K, Bloco 1), cross-checking electronic tax documents (NF-e, NFC-e, CT-e, MDF-e), physical-financial inventory reconciliation, and detecting fiscal fraud (fictitious liabilities, unexplained cash surpluses, omitted revenues, and shell companies).

10%

Direito Administrativo, Civil, Penal e Empresarial

Administrative Law: New Public Bidding and Administrative Contracts Law (Lei nº 14.133/2021: procurement modalities, bidding exemption vs unenforceability), administrative acts and powers, statutory regime of civil servants in Minas Gerais (Lei Estadual nº 869/1952) and AFRE career statute (Lei Estadual nº 15.464/2005); Crimes against the Tax Order (Lei nº 8.137/1990: functional crimes Art. 3º vs private individual crimes Arts. 1º and 2º, STF Súmula Vinculante 24 requirement for definitive administrative assessment, tax embezzlement Art. 2º II, and penal extinction through payment); Business and Corporate Law: Sociedades Limitadas, Sociedades Anônimas (Lei nº 6.404/1976), piercing of the corporate veil (Art. 50 Código Civil), Bankruptcy and Judicial Recovery Law (Lei nº 11.101/2005: priority order of tax and labor credits in liquidation).

10%

Raciocínio Lógico-Quantitativo, Estatística e Matemática Financeira

Financial Mathematics: compound interest, nominal vs effective vs real interest rates (Fisher equation), rational and commercial discounting, amortization systems (SAC vs Price table); Descriptive and inferential statistics: measures of central tendency (mean, median, mode), measures of dispersion (variance, standard deviation, coefficient of variation), conditional probability, Bayes' theorem, discrete and continuous probability distributions (Binomial, Poisson, Normal/Gaussian standard normal Z-scores), confidence intervals, and hypothesis testing (Type I and Type II errors).

How to Pass the SEFAZ-MG Auditor Fiscal Exam

What You Need to Know

  • Passing score: No zero in any discipline of Provas I and II, plus at least 32 of 80 correct in Conhecimentos Gerais and 25 of 50 in Conhecimentos Específicos
  • Assessment: Prova I — Conhecimentos Gerais (80 questions: Língua Portuguesa, Raciocínio Lógico-Matemático, Direito Administrativo, Direito Constitucional e Direitos Humanos, Direito Civil e Empresarial, Direito Penal, Direito Tributário, Contabilidade Geral, Economia e Matemática Financeira); Prova II — Conhecimentos Específicos (50 questions, weighted 2 points each, varying by the chosen Área de Conhecimento); Prova III — written discursive paper with 4 questions of up to 30 lines each.
  • Time limit: Prova I 4h30 and Prova II 3h30 on the same day (morning and afternoon shifts); Prova III 4h30 on a separate date
  • Exam fee: R$ 183,50

Keys to Passing

  • Work through all 100 available questions
  • Review every answer and explanation
  • Track weak areas and revisit them
  • Use our AI tutor for tough concepts

SEFAZ-MG Auditor Fiscal Study Tips from Top Performers

1Master the consolidation of Minas Gerais tax legislation (Lei Estadual nº 6.763/1975) and the structure of the Novo Regulamento do ICMS (Decreto nº 48.589/2023), with particular attention to taxable events, tax base calculations, tax credits, and the Fundo de Erradicação da Miséria (FEM).
2Understand the procedural rules of the RPTA (Decreto nº 44.747/2008), including the 30-day statutory period for administrative defense, default (revelia), requirements of the Auto de Infração, and the appellate jurisdiction of the CCMG.
3Practice multi-step numerical calculations for ICMS-ST (including adjusted MVA formulas for interstate acquisitions), DIFAL under LC 190/2022, and the 1/48 monthly CIAP appropriation for fixed assets.
4Thoroughly review Brazilian Accounting Pronouncements (CPCs) and SPED Fiscal registers (especially Blocos C, E, G, H, and K) to master tax-accounting cross-checking techniques used in fiscal audits.
5Study key STF/STJ jurisprudence affecting state taxation, including ADC 49 (non-incidence on inter-branch merchandise transfers), Súmula Vinculante 24 (penal liability for tax crimes), and Tema 69 STF (exclusion of ICMS from PIS/COFINS bases).

Frequently Asked Questions

What is the primary role of an Auditor Fiscal da Receita Estadual (AFRE) at SEFAZ-MG?

An AFRE at SEFAZ-MG exercises exclusive state tax authority to audit commercial, industrial, and service taxpayers across Minas Gerais, examine accounting records and electronic fiscal books (SPED Fiscal / ECD), constitute state tax credits (ICMS, IPVA, ITCD, and Taxas Estaduais) via formal Auto de Infração, combat tax evasion and fraudulent tax planning schemes, and judge administrative tax litigation at the Conselho de Contribuintes do Estado de Minas Gerais (CCMG).

What are the administrative tax dispute bodies in Minas Gerais (RPTA)?

Under Minas Gerais State Decree nº 44.747/2008 (Regulamento do Processo Tributário Administrativo - RPTA), administrative tax challenges against an Auto de Infração are judged within the Conselho de Contribuintes do Estado de Minas Gerais (CCMG). First instance judgments occur in Câmaras de Julgamento, and appeals can be taken to the Câmara Especial through Recurso de Revisão under specific divergence criteria.

What academic degrees are required for SEFAZ-MG Auditor Fiscal da Receita Estadual?

Candidates must hold an officially recognized bachelor's level higher education degree (diploma de graduação de nível superior) in any area of knowledge, issued by an institution accredited by the Brazilian Ministry of Education (MEC). Specific tracks (such as Tributação, Auditoria, or Tecnologia da Informação) may have additional specialized criteria if specified in the edital.

What is the passing threshold for the SEFAZ-MG objective examination?

Candidates must obtain at least 50% of the total possible points in Prova Objetiva 1 (Conhecimentos Gerais), at least 50% in Prova Objetiva 2 (Conhecimentos Específicos), and at least 60% of the aggregate total points across both papers, in addition to achieving the minimum qualifying grade in the Prova Discursiva.

How does Minas Gerais handle ICMS Substituição Tributária (ICMS-ST) restitution?

Pursuant to the landmark Supreme Court ruling in RE 593.849 (Tema 201 STF) and Minas Gerais RICMS provisions (Art. 22 do RICMS-MG), the substituted taxpayer has the right to restitution of the ICMS-ST paid in excess when the actual effective retail sales price is lower than the presumed statutory tax base calculated via MVA, provided proper electronic restitution procedures are followed.