Brazil: Corporate tax measures in pending tax reform

Updated version includes proposals that would affect corporate taxpayers.

Updated version includes proposals that would affect corporate taxpayers.

A new version of a tax reform bill was presented earlier this week.

A new version in the form of a substitute was presented for Bill No. 2337 of 2021. The updated version includes proposals that would affect corporate taxpayers in areas concerning:

  • Corporate income tax rate (IRPJ)
  • Dividend distribution
  • Deductibility of interest on equity (JCP)
  • Anti-deferral rule for individuals
  • Obligation to opt for the actual profit proposed for some real estate companies and companies operating voice and image rights
  • Capital gains and losses of assets
  • Goodwill deductibility
  • Exchange variation on investment abroad
  • Capital reduction in assets or rights delivered to controlling partners or partners with significant influence in the previous year and in the following 12 months
  • Payment of capital in companies and other entities abroad
  • Taxation regime applicable to SCPs and ostensible partner
  • Capital gain obtained from the indirect sale of assets located in Brazil
  • Rate applicable to income from investments in bonds and securities and open-end Investment Funds
  • Minimum composition of equity of Equity Investment Funds
  • FIDC and FIC FIDC taxation rules
  • Taxation rules for Investment Funds in Market Indexes
  • Income tax rate considered credited and paid on 1 January 2022 to shareholders of closed-end funds and FIPs not qualified as investment entities
  • Inapplicability of the taxation regime for investments in closed-end funds
  • Real estate investment funds
  • Updating of assets and rights held abroad by the individual
  • Revocation of tax benefits
  • PIS and COFINS—Special regimes

Other items concerning individual income tax measures are generally unchanged.

Read an August 2021 report (Portuguese) prepared by the KPMG member firm 


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