The state of Espírito Santo is, admittedly, a unit of the federation that supports enterprises in the most diverse segments, having started its range of benefits through the institution of FUNDAP, an incentive for foreign trade operations.

Following this philosophy of promoting business development and generating jobs and income, for some years it has been offering yet another important benefit, the Special Substitute Tax Regime (we simply call it REOA).

By granting the Substitute Taxpayer claim, the wholesale company or even retailer (must be analyzed on a case-by-case basis) becomes the first link in the ICMS - ST (TAX SUBSTITUTION) chain, failing to acquire its goods with this tax.

The ICMS-ST calculation system, as established in its legislation, places the importing industry as the first link in its chain, so the Wholesaler or Retailer already receives its goods with the normal ICMS plus ICMS-ST, which it places a heavy burden on such goods until they reach final consumers.