Brazil has enacted legislation reducing the CSLL rate for local reinsurance companies to 9% from 2027 and removing the additional IRPJ rate from 2030, while providing more flexible rules for using tax losses
Brazil’s President has sanctioned Law No. 15,525/2026 of 28 September 2026, establishing a specific corporate tax framework for local reinsurance companies in Brazil. The Official Gazette published Law No. 15,525/2026 on 29 September 2026.
The aim of this law is to correct the tax asymmetry between local and foreign reinsurers and strengthen the domestic reinsurance market. Law No. 15,525 also amends the rules on the Social Contribution on Net Profits (CSLL), corporate income tax (IRPJ), and the use of tax losses by local reinsurance companies.
CSLL rate reduced
From 1 January 2027, the CSLL rate for local reinsurance companies will be reduced to 9%. The measure applies to local reinsurance companies covered by Article 4(I) of Complementary Law No. 126/2007.
IRPJ surcharge removed
From 1 January 2030, the additional IRPJ rate will no longer apply to local reinsurance companies. The law amends the relevant provisions of Law No. 9,249/1995 and Law No. 9,430/1996 to exclude these companies from the additional tax.
Tax loss utilisation
Law No. 15,525 also introduces special rules for the utilisation of tax losses and negative CSLL calculation bases. The existing 30% limitation on the annual offset of these amounts will not apply where losses incurred by local reinsurance companies have not been fully utilised within three years of being incurred. The measure also covers tax losses and negative CSLL bases incurred before the law was published, provided they remain partially or fully unutilised.
Effective dates
The law entered into force upon publication in the Official Gazette on 29 September 2026.
The provisions reducing the CSLL rate and introducing the special tax-loss rules will apply from 1 January 2027, while the provisions removing the additional IRPJ rate will apply from 1 January 2030.
Earlier, Brazil’s Senate approved Bill 3.540/2026, proposing a 9% CSLL rate and removal of the 30% tax loss offset limit for local reinsurers to improve their competitiveness.
