Tax & International Structuring in Brazil

Essentials guide · Source-checked research100% of statements checked against a source51 checked against an official source0 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed

• Corporate income tax (IRPJ) is 15% of taxable profit, plus an additional 10% on the portion of profit exceeding BRL 20,000 per month.

  Applies under real, presumed or arbitrated profit regimes; the BRL 20,000 is multiplied by the number of months in the assessment period.Receita Federal do Brasil · checked 2026-10-19

• The social contribution on net profit (CSLL) is 9% for legal entities in general and 15% for entities treated as financial institutions, private insurers and capitalisation companies.

  Rates in force since 1 May 2008 per the page; certain financial institutions are subject to different rules not detailed here.Receita Federal do Brasil · checked 2026-10-19

• Brazil applies a domestic minimum top-up tax (Adicional da CSLL) of up to the gap to a 15% effective rate for constituent entities of multinational groups with annual revenue of EUR 750 million or more in at least two of the four preceding years, from 1 January 2025.

  Pillar Two QDMTT under Lei 15.079/2024; payment due by the last business day of the seventh month after the fiscal year end.Receita Federal do Brasil · checked 2026-10-19

• Profits or dividends paid, credited or remitted abroad are subject to 10% withholding income tax from 1 January 2026, except profits relating to results up to calendar year 2025 whose distribution was approved by 31 December 2025.

  Non-resident beneficiaries; an optional credit mechanism (Lei 9.249/1995, art. 10-A) may be claimed within 360 days, subject to regulation. Treaties may affect the rate.Presidência da República (Planalto) · checked 2026-10-19

• Under the consumption tax reform, 2026 is a test year in which CBS is charged at 0.9% and IBS at 0.1%, offset against PIS and Cofins; in 2027 PIS and Cofins are extinguished, IPI falls to zero except to protect the Manaus Free Trade Zone, and the Selective Tax (Imposto Seletivo) starts.

  Federal CBS replaces PIS/Cofins; IBS is shared by states and municipalities. In 2027 and 2028 IBS is charged at 0.1% and CBS at its rate reduced by 0.1 point. Test-year amounts are waived for taxpayers meeting their reporting obligations.Receita Federal do Brasil · checked 2026-10-19

• State ICMS and municipal ISS are phased into IBS from 2029 to 2032 (IBS 10%, 20%, 30% and 40% of the new burden in successive years) and are extinguished in 2033, when the new model applies in full.

  All taxpayers in the ICMS and ISS bases.Receita Federal do Brasil · checked 2026-10-19

• Employers pay a social security contribution of 20% on the total remuneration paid, due or credited to employees during the month.

  General rule for legal entities; sector regimes (such as payroll-tax relief schemes) may differ.Receita Federal do Brasil · checked 2026-10-19

• Under the consumption tax reform, IPI is kept from 2027 only to preserve the competitiveness of the Manaus Free Trade Zone (Zona Franca de Manaus).

  IPI rate reduced to zero for almost all products from 2027 except those industrialised in the Zona Franca de Manaus.Receita Federal do Brasil · checked 2026-10-19

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