Introduction of dividends taxation in Brazil
On November 26, 2025, Law No. 15,270/2025, which deals with income tax reform, was enacted without vetoes by the President.
This is the conversion of Bill 1,087/25, with the objective of (i) reducing to zero the personal income tax (“IRPF”) for those earning up to R$ 5,000.00 per month, (ii) offering a discount on the IRPF for those earning up to R$ 7,350.00 per month, (iii) covering this tax waiver with the reintroduction of income tax on the distribution of dividends, including to non-residents, combined with the creation of a minimum personal income tax (“IRPFM”) for those earning above R$ 600,000.00 annually.
The new Law will enter into force on the date of publication, with effects from January 1, 2026.
The main points of the law are:
Brazilian Federal Revenue Service expands rules for crypto assets and implements new rules for declaring crypto assets in 2026
The Brazilian Federal Revenue Service has released Normative Instruction RFB No. 2,291/2025, which redefines and expands the obligations for declaring cryptocurrency transactions in Brazil. This regulation comes a week after the Central Bank (BC) included digital currency exchanges, such as Bitcoin, in the same regulatory framework applied to traditional financial institutions.
The new regulation updates the requirements established since 2019, aligns the country with international transparency standards set by the OECD and the G20, and introduces a standardized form for declarations: the Cryptoasset Declaration (DeCripto).
Among the most relevant changes is the mandatory requirement for foreign exchanges operating in Brazil to submit the same declarations required of national operators, something that was not foreseen in the previous regulation.
With the new regulation, Brazil will implement the Crypto-Asset Reporting Framework (CARF), an international protocol created by the OECD in 2022 to standardize the instant exchange of information on cryptocurrency transactions. CARF works similarly to the automated data interchange system already used for traditional financial transactions. The idea is to create a global network for traceability of digital currency operations.
Operators will be required to report information such as: Identification of reportable individuals; Cryptocurrency used in the transaction; Number of transactions per type of transaction; Total value, in reais (Brazilian currency), of each transaction; Total quantity of cryptocurrencies per type of transaction.
The Chamber of Deputies is expected to vote on the regulation of the tax reform in December
The approval of PLP 108 is crucial because the regulation of the Tax on Goods and Services (IBS) and the Contribution on Goods and Services (CBS) cannot move forward without the enactment of the law. Technicians working on drafting the internal regulations have expressed concern about the possibility of a very short interval between the publication of the law and the official release of the regulation.
In the IBS Management Committee, the concern is even greater. Currently, only the states formally comprise the superior council. Municipalities will only join the body after the enactment of the new law, and without this participation, it is impossible to finalize the signing of the regulation.
At the Federal Revenue Service, the assessment is similar: any delay compromises the implementation schedule and reduces the time for internal adjustments, system testing, and guidance to taxpayers.
One of the areas of potential revision involves changes approved by the Senate in September 2025 that alter provisions already established in Complementary Law 214/2025, which regulated the first stage of the reform. Among the sensitive points are rules related to administrative litigation judgments, which may be debated again in the new round of analysis.
Tax authorities postpone IBS/CBS validation and prevent rejection of invoices until January 2026
The Brazilian tax authority has decided that filling in the fields related to IBS/CBS will not be required by validation rules in January 2026, as previously planned. This decision was formalized in Technical Note 1.33, signed by the Federal Revenue Service and ENCAT (National Meeting of State Tax Coordinators and Administrators). The decision comes on the eve of the new year and represents a relief for companies that were still in the process of adapting their systems.
The postponement means that invoices issued from January 2026 onwards will not be rejected due to the lack of completion of IBS/CBS fields during authorization. However, the Technical Note clarifies that providing information related to the new taxes remains mandatory according to current legislation, even if the absence of this information does not generate rejection in the authorization environment.
The document states that the "start of the mandatory reporting of the new taxes (RV UB12-10)", established in version 1.30, is subject to "future implementation", without a defined date. The absence of an official date reinforces that the timeline depends on further technical communications.
The decision was already anticipated by market players and companies that reported delays in technological adaptation processes. Even so, the tax authorities emphasize that the easing of restrictions should be received with caution, since the mandatory validation of IBS/CBS fields will be implemented in the coming months.regarding the sector's taxation. He pointed out that the average effective tax rate for fintechs in the last two years has exceeded that of banks: in 2024, 29.7% versus 12.2%; in 2023, 36.5% versus 8.9%. According to him, banks have accumulated tax credits and tax benefits related to Interest on Equity (JCP).
Taxation on streaming services advances in the Chamber of Deputies
The Chamber of Deputies approved the main text of the bill that creates a new tax on audiovisual streaming services.
The approved text establishes that companies offering access to audiovisual content over the internet, such as streaming platforms, will be required to pay the Contribution for the Development of the National Film Industry (Condecine). The contribution will vary from 0.1% to 4% of annual gross revenue, excluding indirect taxes and including advertising revenue.
The new levy will cover video-on-demand (VoD) services, such as Netflix, app-based TV services, such as Claro TV+, and video-sharing platforms, such as YouTube.
According to the proposal, video-on-demand and app-based TV services will pay between 0.5% and 4%, with fixed deductions ranging from R$ 24,000 to R$ 7.14 million, distributed across five tiers. Sharing platforms will have rates of 0.1% to 0.8%, with deductions between R$ 4,800 and R$ 1.4 million.
Since Condecine aims to promote the national audiovisual industry, the text allows companies to deduct up to 60% of the contribution if they allocate that amount to Brazilian audiovisual production. This deduction will apply to video-on-demand and app-based TV services.
Senate approves bill allowing property value updates for income tax purposes
Law No. 15,265/2025, enacted in November 2025, established the Special Regime for Updating and Regularizing Assets (REARP). This new regime allows taxpayers to update the value of certain assets (such as real estate and vehicles) to their market value, paying a reduced income tax rate, much lower than the standard taxation on capital gains.
Furthermore, the law offers the opportunity to regularize assets and property not previously declared, through the payment of a special tax.
REARP is an optional program created by the government to facilitate the updating of asset values and the regularization of assets with the tax authorities. Its main objective is to correct a historical distortion in the Brazilian tax system: until then, individuals could not update, in their annual income tax return, the acquisition value of real estate and other long-term assets, even after years of inflation and appreciation.
This meant that the declared value was significantly outdated compared to the market value, resulting in taxation on a capital gain, largely fictitious (resulting only from accumulated inflation), at the time of the sale of the asset.
With REARP, the government allows taxpayers to pay a reduced tax in advance on the appreciation of their assets, aligning the declared value with the current market value. In return, the government anticipates revenue that would only occur upon the future sale of these assets (or perhaps would not even occur if the taxpayer avoided selling due to high taxation). The program also encourages tax compliance by offering a way for undeclared assets to finally be included in income tax, through the payment of fines and taxes, voluntarily expanding the tax base.
In summary, REARP has two main aspects: (1) updating the asset valuation of already declared assets, with preferential taxation on the difference in value; and (2) regularizing undeclared assets, with the payment of taxes and fines to become compliant with tax authorities.
