The law introduces tax measures, including reduced effective corporate tax rates, a 10% withholding on dividends to foreign recipients and high-value individual dividends, and a minimum tax on individuals.
Brazil published Law No. 15.270 in the Official Gazette, enacting several tax measures for companies, including a corporate minimum tax and withholding tax on dividends, on 27 November 2025.
This follows after Brazil’s Senate passed Bill 1087/25 on 5 November 2025, which included these tax measures.
The key tax measures of Bill 1087/25 are as follows:
Reduction rules for minimum tax
Bill 1087/25 provides that if the combined corporate tax and minimum dividend tax exceed the nominal rates, the effective tax will be reduced to 34% for standard corporations, 40% for financial institutions, and 45% for insurance companies.
Withholding tax on dividends paid abroad
A 10% withholding tax will apply to dividends or profit distributions to foreign recipients, with exemptions for distributions up to 2025, if approved by 31 December 2025, payments to foreign governments with reciprocal treatment, sovereign wealth funds, and foreign entities managing social security or pensions. Any excess tax paid over nominal corporate rates can be claimed as a credit within 360 days.
Withholding tax on high-value dividends for individuals
A 10% withholding tax will be applied to dividends or profit distributions paid by the same company to the same individual when monthly payments exceed BRL 50,000.
Minimum tax on high individual incomes
A minimum tax will apply to individuals earning over BRL 600,000: 10% for income equal to or above BRL 1.2 million, and a progressive rate of 0–10% for income between BRL 600,000 and BRL 1.2 million.
The new rules will generally take effect from January 2026.
