Brazil's tax authority implements a progressive system for presumed profit taxation, adding a 10% surcharge on corporate income calculations for businesses earning above BRL 5 million annually, with quarterly adjustments and year-end reconciliation mechanisms taking effect from 23 January 2026.
Brazil’s tax authority, the Federal Revenue Service (RFB) issued Normative Instruction No. 2,306 on 23 January 2026, modifying the taxation framework for companies operating under the presumed profit regime. The changes establish a tiered system that affects businesses with substantial annual revenues.
Companies taxed under the presumed profit method will face a 10% increase in their presumption percentages for Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL). However, this adjustment only applies to revenue exceeding BRL 5 million per year.
The government has implemented a quarterly distribution system, setting the threshold at BRL 1.25 million per quarter. Businesses surpassing this limit in any given quarter must apply the higher presumption rates only to the portion of revenue above the threshold.
The regulation allows companies to adjust calculations throughout the year. If a business earns less than BRL 1.25 million in one quarter, it can carry forward the unused portion to subsequent quarters within the same calendar year.
At year-end, companies must reconcile their total annual revenue. Those falling below the BRL 5 million threshold can recalculate their tax obligations, potentially claiming refunds or credits for overpayments made during earlier quarters. These credits will accrue interest based on the Special System for Settlement and Custody (Selic) rate, plus 1% in the month of availability.
For companies with diverse activities subject to different presumption rates, the 10% increase must be applied proportionally based on each activity’s revenue contribution. Businesses starting or closing operations mid-year will have their annual threshold calculated proportionally based on active quarters.
Normative Instruction No. 2,306 took effect immediately upon publication in the Official Gazette and supersedes conflicting provisions from the previous Normative Instruction No. 2,305 issued on 31 December 2025.
