01/12/2026
At the end of 2025, several tax regulations were enacted, bringing significant changes to the Brazilian tax landscape. Among them, Complementary Law No. 224, of December 26, 2025 (LC No. 224/2025) stands out for reducing federal tax benefits, amending the calculation basis of the Corporate Income Tax (IRPJ) and the Social Contribution on Net Profit (CSLL) under the Presumed Profit regime, and increasing the withholding income tax rate applicable to Interest on Net Equity (JCP).
With respect to federal tax benefits granted by the Union, LC No. 224/2025 introduced an approximately 10% reduction in several federal tax incentives, affecting taxes such as IRPJ, CSLL, PIS, Cofins, the Tax on Industrialized Products (IPI), and Import Tax (II). The law also established new criteria and procedures for the granting, expansion, or extension of such incentives, with stricter requirements regarding the assessment of fiscal impacts and compliance with governance and transparency standards.
The complementary law also implemented relevant changes to the Presumed Profit regime, by determining a 10% increase in the presumed profit margins applied to gross revenue for purposes of calculating IRPJ and CSLL. This increase applies exclusively to the portion of annual gross revenue that exceeds BRL 5,000,000.00, primarily affecting medium-sized companies that adopt this taxation regime.
In practical terms, a service company with annual gross revenue of BRL 10,000,000.00 that calculates IRPJ and CSLL under the Presumed Profit regime previously paid approximately BRL 1,064,000.00 in these taxes (equivalent to 10.64% of its gross revenue). Following the changes introduced by LC No. 224/2025, the amount due increases to approximately BRL 1,118,400.00 (11.18% of gross revenue), representing an effective increase of around 5% in the tax burden.
Finally, LC No. 224/2025 also increased the withholding income tax rate on Interest on Net Equity (JCP) from 15% to 17.5%. The law was regulated by Decree No. 12,808/2025 and Brazilian Federal Revenue Service Instruction Normative (IN RFB) No. 2,305/2025, with most of its provisions already in force.
Our tax team is available to provide clarifications and guidance on this matter.
Co-authored by: Phillipe da Cruz Silva
