Changes to the Presumed Profit rules and an increase in the IRPJ and CSLL tax base starting in 2026
Complementary Law No. 224/2025, published on December 26, 2025, establishes new guidelines for granting, reducing, and monitoring federal tax incentives and benefits, with a direct impact on special tax regimes, including the Presumed Profit regime.
With the new rule the regime is formally classified as a tax benefit at the federal level. Among the main changes, the law mandates a 10% increase in the presumption percentages applicable to the calculation base of the Corporate Income Tax (IRPJ) and the Social Contribution on Net Profit (CSLL) on the portion of annual gross revenue that exceeds R$ 5 million.
Although the changes will take effect from 2026, the additional CSLL (Social Contribution on Net Profit) payment will not be required in the first quarter of the year, due to the principle of the ninety-day prior notice period. Since the law was published on December 26, 2025, the requirement for this increase can only occur after a minimum period of 90 days.
Therefore, the practical application of the increased tax base for CSLL under the Presumed Profit regime is likely to occur from the second quarter of 2026, in accordance with constitutional rules and current administrative regulations.
Brazil raises import tax by up to 7.2%, mainly affecting smartphones, machinery, and capital goods
The Federal Government has formalized the increase in import tax through Resolution Gecex No. 852/2026, which has been in effect since February 5th. The decision mainly affects capital goods, such as machinery and production equipment, as well as information technology and telecommunications goods.
According to the Ministry of Finance, imports of capital goods and IT equipment have grown by 33.4% since 2022, and the penetration of these products in national consumption exceeded 45% in December of last year, and these levels "threaten to collapse links in the production chain and cause productive and technological regression in the country."
Despite the tariff increase, the government announced that it will be possible to request a temporary reduction of the rate to zero until March 31st, in cases of products that previously benefited from the exemption. The temporary concession may be valid for up to 120 days.
New US Tariff Regime Eliminates Fees for Brazilian Aircraft and Benefits Export Sectors
The changes come after a decision by the United States Supreme Court that invalidated the broad application of tariffs on imports based on national emergency legislation. In response, the US government announced the adoption of a global tariff of 10%, with a later indication of a possible increase to 15%, still pending formalization.
The new tariff rules announced by the United States now exclude aircraft manufactured in Brazil from the incidence of additional tariffs, guaranteeing a zero rate for the entry of these products into the US market, according to information from the federal government. Before the change, Brazilian aircraft were subject to a 10% tariff, which directly impacted the competitiveness of the export sector.
This new tariff also covers other relevant industrial sectors, such as machinery and equipment, footwear, furniture, clothing, wood, chemical products, and ornamental stones. These segments will no longer face higher rates and will now compete under the global tariff announced by the United States, initially set at 10% and later mentioned at 15%, although not yet formalized by executive order. In the agricultural sector, items such as fish, honey, tobacco, and instant coffee will also be subject to the global tariff, moving from higher rates to the 10% or eventual 15% range. Approximately 29% of exports remain subject to specific tariffs applied under Section 232, which remain unchanged.
Copom maintains Selic at 15%
The Monetary Policy Committee (Copom) of the Central Bank of Brazil decided to maintain the basic interest rate (Selic) at 15.00% per year, as deliberated at the meeting held on January 27 and 28, 2026.
The decision was unanimous among the members of the committee, but at the same time the Committee indicated that it considers it appropriate to signal the beginning of a cycle of interest rate reductions at its next meeting, conditional on confirmation of the expected scenario for inflation.
The signaling occurs in the context of cooling inflation, gradual improvement in current inflationary conditions and clearer evidence of the transmission of monetary policy, according to the minutes released by the Central Bank.
Tax Reform – Updates
CBS Beta Production Environment: The Brazilian Federal Revenue Service has made available the CBS (Contribution on Goods and Services) Beta Production Environment, a platform created so that taxpayers can test and gradually adapt to the new rules of the Consumption Tax Reform. The system allows technical simulations without generating effective financial obligations and will remain open throughout 2026.
CBS Rate: For the final phase, 2027, the CBS rate has been set at 8.8%. Before that, there will be a transition period, starting in 2026, when the CBS will be applied on a trial basis, with a reduced percentage of 0.9%.
Brazilian Federal Government Proposes Taxation on Crypto with a 3.5% IOF
The federal government plans to put out for public consultation a proposal to tax the purchase of crypto and other digital assets with a 3.5% IOF (Tax on Financial Operations), a percentage that currently does not exist for this type of operation. The initiative is being conducted by the Ministry of Finance and aims to assess, together with society, the convenience of taxation and the definition of possible exemption limits.
According to the proposal under study, the initial idea is that IOF will be charged on crypto purchases starting at R$ 10,000. The final cutoff value, however, is not yet defined and will depend on the result of the public consultation.
The government's diagnosis is that there has been exponential growth in crypto transactions in recent years, and these digital assets have begun to enjoy a tax advantage over traditional foreign exchange transactions, which are already subject to IOF.
Given this scenario, the understanding is that it would be necessary to create equal tax treatment between conventional financial operations and transactions involving crypto-assets, reducing distortions in the tax system.
With the opening of public consultation, the government begins the formal process of discussing the proposal to tax crypto via IOF, but only after analyzing the contributions and assessing the impacts will the eventual issuance of a decree to institute the tax be defined.
Until then, there has been no change in the tax rules currently in force for operations with crypto-assets.
