The Brazilian government enacted Law No. 15,265/2025¹ on November 21, 2025, establishing the Special Regime for Asset Update and Regularization (REARP). The new law introduces significant opportunities for individuals to update the value of certain assets and regularize previously undeclared or incorrectly declared assets and rights if they take action by February 19, 2026.
WHY THIS MATTERS
Law 15,265/2025 provides a legal framework for individuals to regularize and update assets, potentially reducing future tax risks and penalties. The regime applies to assets acquired up to December 31, 2024, and offers definitive tax rates and procedures for compliance. This is particularly relevant for individuals with assets in Brazil or abroad, including expatriates and those with cross-border holdings.
Executive Summary
Asset Update | Regularization of Assets/Rights | |
Eligibility | Tax residents in Brazil as of December 31, 2024. | • Tax residents in Brazil as of December 31, 2024. • Non-residents in 2025 who were residents as of December 31, 2024. |
Covered Assets | Real estate and movable assets subject to public registry. | Lawful resources, assets, or rights not reported, or reported incorrectly. |
Tax Rate | 4 percent on the difference between previous and updated amounts. | 15 percent on the regularized amount. |
Penalty | Not applicable | 100 percent on the tax due |
Requirements | Sale within 5 years (real estate) or 2 years (movables) cancels regime effects, except for legal exceptions. | Requires proof of lawful origin; includes estates and assets without balance/formal ownership. |
REARP on Assets Updates
Allows updating the value of registered movable and immovable assets (e.g., vehicles, real estate, etc.) in Brazil or abroad, acquired up to December 31, 2024, provided the assets were reported in the taxpayer’s Annual Individual Income Tax Return.
Conditions and Requirements:
- For individuals, updating asset values triggers a definitive 4 percent income tax on the difference between the updated value and acquisition cost.
- It is not applicable to assets sold before opting in.
- Sale of updated assets within 5 years (for real estate) or 2 years (for movables) after joining REARP, cancels the regime’s effects—excluding some legal exceptions. Capital gains tax (15 percent) applies, deducting the update tax paid (4 percent as above), adjusted by “Selic” interest rate (the benchmark interest rate for the Brazilian economy, set-up by the Central Bank of Brazil).
REARP for Regularization of Assets and Rights
Enables regularization of lawful assets not reported, or reported with omissions/errors, including bank deposits, financial instruments, shares, intangibles (brands, patents, crypto assets), real estate, vehicles, among others.
Conditions and Requirements:
- Imposes a 15 percent income tax on the regularized value, plus a 100 percent penalty on the tax amount.
- Applies to assets and/or rights without balance or formal ownership as of December 31, 2024.
- Requires documentation proving reported value and lawful origin, not exceeding market value.
- Regularized assets and/or rights must be reported in the 2024 Annual Individual Income Tax Return, or its amendment.
- Income from regularized assets in 2025 must be reported and taxed.
Procedures for Joining REARP
- Adherence must occur within 90 days of the law’s publication (November 21, 2025, until February 19, 2026), via a specific declaration and payment of the applicable taxes. These payments are definitive and non-refundable.
- Payment can be made on a single installment, or up to 36 monthly installments (for taxes higher than BRL 2,000 and being the minimum of BRL1,000 per installment). The first installment is due by the last business day of the declaration’s month, being the subsequent installments accrued by the “Selic” interest rate (the benchmark interest rate for the Brazilian economy, set-up by the Central Bank of Brazil).
Extinction of Criminal Liability
Full payment of taxes and compliance with legal conditions, before a criminal conviction, extinguishes liability for tax crimes listed in the law, for assets and/or rights updated or regularized under REARP.
KPMG INSIGHTS
KPMG in Brazil states that, individuals and organizations may wish to consider analyzing the impact of REARP on their asset portfolios and tax planning. Timely compliance can mitigate risks and optimize tax positions.
For further guidance, consult your qualified tax professional or a member of the GMS tax team with KPMG in Brazil (see the Contacts section).
FOOTNOTE:
1 To see (in Portuguese) Law No. 15,265/2025, Presidency of the Republic of Brazil website: “Lei Nº 15.265 de 21 de novembro de 2025,” published on November 21, 2025.
Contacts
Disclaimer
The information contained in this newsletter was submitted by the KPMG International member firm in Brazil.
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