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In force

Income tax reform: zero tax up to R$ 5,000 a month and a minimum tax on high incomes (Law 15.270/2025)

Law No. 15.270 of 26 November 2025 amends Brazil’s personal income tax. Since January 2026, a tax reduction cancels the monthly tax on taxable income up to R$ 5,000 and phases out between R$ 5,000.01 and R$ 7,350. To offset the cost, profits and dividends above R$ 50,000 a month paid by one company to one resident individual bear a 10% withholding, dividends sent abroad a 10% withholding, and individuals with total annual income above R$ 600,000 owe a minimum tax rising to 10%, settled from the 2027 annual return. Submitted by the government in March 2025, the bill was passed by the Chamber of Deputies on 1 October and by the Senate on 5 November 2025. Several of its dividend provisions are challenged before the Supreme Federal Court.

Citoyen·Updated: November 10, 2026

Key points

High-income taxpayers expected to pay more

140,000

income of 2026 onwards · Announced

according to the Ministry of Finance, at the signing of the law (26 November 2025)[7]

Estimate (« 140 mil brasileiros de alta renda »), annual income above R$ 600,000.

Maximum rate of the minimum tax on high incomes

10%

annual income of R$ 1.2 million or more, from 2026 · Observed

Law No. 15.270/2025, article 2 (new article 16-A of Law 9.250/1995)[1]

Gini index

50.3index

2024

World BankSee the card →

Mandatory levies

15.4% GDP

2024

World BankSee the card →
  • Status: In force since January 1, 2026. The monthly reduction and the 10% withholding on dividends apply from January 2026; the annual reduction and the minimum tax apply to income of 2026, settled in the 2027 annual return.[1][10]
  • Next milestone: 2027, First annual return applying the annual reduction and the minimum tax (income of 2026)

At a glance

Reference text

Lei nº 15.270, de 26 de novembro de 2025 (Law No. 15.270 amending Laws No. 9.250 and No. 9.249 of 1995 to reduce the income tax due on the monthly and annual bases and to set a minimum tax on individuals with high incomes)[1]

No. Lei nº 15.270/2025 · November 26, 2025

Read the text ↗

Carried by

  • Luiz Inácio Lula da Silva[2][1]President of the Republic, submitted the bill to Congress (March 2025) and signed the law on 26 November 2025 · 2025 · Initiator
  • Fernando Haddad[3]Minister of Finance, signed the explanatory memorandum of the bill (EM No. 19/2025, 15 March 2025) · 2025 · Initiator
  • Arthur Lira[2][4]Deputy (PP-AL), rapporteur of the special committee and in plenary in the Chamber of Deputies; his substitute text raised the ceiling of the partial reduction from R$ 7,000 to R$ 7,350 · 2025 · Amendment
  • Renan Calheiros[6]Senator, rapporteur in the Economic Affairs Committee and in plenary; recommended approval with drafting amendments only · 2025 · Amendment

Implementation

  • Federal Revenue Service (Receita Federal do Brasil): rules, withholding guidance, annual returns
  • Employers and other paying sources (monthly withholding) and companies paying dividends
  • Ministry of Finance, Secretariat for Economic Policy (annual assessment announced in the explanatory memorandum)

Stated objective

Make personal income taxation more even and more in line with progressivity according to each taxpayer’s ability to pay: relieve lower-income workers, freeing income for priority needs, and correct the « inverse progression » observed at the top of the distribution, where the effective rate falls as income rises because of deductions and exemptions, notably on profits and dividends. The cost of the relief is to be offset by the minimum tax on high incomes and the withholding on dividends sent abroad.[3]

according to the explanatory memorandum of the Ministry of Finance (EM No. 19/2025, March 2025)

  • People who stop paying income tax

    10,000,000

    from 2026 · according to the Ministry of Finance, at the signing of the law (26 November 2025)[7]

    Approximate figure (« 10 milhões »).

  • People whose income tax is reduced

    5,000,000

    from 2026 · according to the Ministry of Finance, at the signing of the law (26 November 2025)[7]

    Approximate figure (« 5 milhões »).

Main measures

  • Monthly reduction (new article 3-A of Law 9.250/1995): from January 2026, a reduction of up to R$ 312.89 brings the monthly tax to zero on taxable income up to R$ 5,000; between R$ 5,000.01 and R$ 7,350 the reduction falls linearly (R$ 978.62 − 0.133145 × income) and disappears above R$ 7,350. It also applies to the 13th-month salary.[1][8]
  • Annual reduction (new article 11-A): from the 2027 return (income of 2026), no reduction above R$ 88,200 of annual taxable income; according to the Federal Revenue Service, annual taxable income up to R$ 60,000 is no longer taxed. The cap of the simplified deduction rises to R$ 17,640 from 2026.[1][8]
  • Monthly withholding on dividends (new article 6-A): profits and dividends paid by the same company to the same individual resident in Brazil above R$ 50,000 in a month bear a 10% withholding on the whole amount, with no deduction; it is an advance on the annual minimum tax. Profits from results up to 2025 whose distribution was approved by 31 December 2025 are excluded.[1][3][10]
  • Annual minimum tax (new article 16-A): individuals whose total income for the year exceeds R$ 600,000, including exempt and exclusively taxed income, owe a minimum rate rising linearly from 0% to 10% up to R$ 1.2 million, then 10%. Excluded from the base: capital gains (except on exchange-traded operations), inheritances and gifts, savings accounts, several tax-exempt real-estate and agribusiness securities, damages, among others. Income tax already paid is deducted.[1][7]
  • Ceiling on combined taxation (new article 16-B): when the company’s effective tax rate on its profits plus the shareholder’s effective minimum-tax rate exceeds 34% (45% for banks, 40% for insurers and other financial institutions), the minimum tax is reduced by the excess.[1][3]
  • Dividends sent abroad (Law 9.249/1995, article 10 §4 and new article 10-A): 10% withholding, except for foreign governments with reciprocity, sovereign funds and foreign pension entities; a credit is available when the combined taxation exceeds the same ceilings.[1]
  • Other provisions (articles 4 to 6): states and municipalities are compensated for their revenue loss, by the Union quarterly if the increase of their participation funds falls short; any federal revenue surplus counts towards the reference rate of the new goods and services contribution (CBS); within one year, the executive must send Congress a bill on a national policy for updating income tax amounts.[1]

In data

Gini index

50.3index

2024

Reducing inequality is the stated aim; survey-based Gini data are published with a lag of one year or more.

World BankSee the card →

Mandatory levies

15.4% GDP

2024

The reform is designed to be revenue-neutral according to the government: lower tax on middle incomes, offset by the minimum tax and the dividend withholdings.

World BankSee the card →

Timeline

  1. March 18, 2025Under debate

    Bill No. 1087/2025 submitted to the Chamber of Deputies with a constitutional urgency request[2][3]

    The executive’s original text set the end of the partial reduction at R$ 7,000 a month.

  2. July 16, 2025

    Special committee of the Chamber adopts the rapporteur’s substitute text[2][4]

    The committee approves Arthur Lira’s report, which raises the end of the partial reduction from R$ 7,000 to R$ 7,350 (about half a million more taxpayers, according to the rapporteur). A motion to vote separately on the monthly taxation of high incomes fails: the chapter is kept by 25 votes to 5.

  3. October 1, 2025

    Chamber of Deputies passes the bill (493 votes for, out of 493)[2]

    The plenary adopts the global substitute sub-amendment of the special committee and the final wording, then sends the bill to the Senate.

  4. November 5, 2025Adopted

    Passed by the Senate, after the Chamber of Deputies (1 October 2025)[6][2][1]

    Signed into law on 26 November 2025 as Law No. 15.270 and published in the Diário Oficial da União on 27 November 2025.

  5. November 26, 2025

    Law signed by the President, published the next day[1][7]

    Law No. 15.270 is signed on 26 November 2025 and published in the Diário Oficial da União on 27 November 2025; it takes effect from 1 January 2026.

  6. December 11, 2025 – December 18, 2025

    Federal Revenue Service publishes the implementing rules[8][9][10]

    Guidance for paying sources on the monthly reduction (11 December), questions and answers on dividends (16 December), then Normative Instruction RFB No. 2299/2025 (18 December). The annual taxation of high incomes is to be regulated later, as it only applies in the 2027 annual return.

  7. December 15, 2025Current step

    Constitutional challenges before the Supreme Federal Court (STF)[11][12][13]

    The national confederations of commerce (CNC, ADI 7912) and industry (CNI, ADI 7914) contest the 31 December 2025 deadline for approving the distribution of 2025 profits free of the new tax; the Brazilian Bar Association (OAB, ADI 7917) contests the application to Simples Nacional small firms. On 26 December 2025 Justice Nunes Marques extended the deadline to 31 January 2026 and rejected the OAB’s interim request. In the virtual session of 13-24 February 2026, after two votes to confirm, the President of the Court took the case out of the virtual session; the referendum is still pending.

  8. January 1, 2026In force

    Effects from 1 January 2026[1][10]

    The monthly reduction and the 10% withholding on dividends apply from January 2026; the annual reduction and the minimum tax apply to income of 2026, settled in the 2027 annual return.

  9. 2027Upcoming: the outcome is not known

    First annual return applying the annual reduction and the minimum tax (income of 2026)[1][10]

    The minimum tax on high incomes is computed for the first time in the 2027 annual adjustment return; the Federal Revenue Service has announced that it will regulate it in due course.

The debate

Citoyen takes no position: arguments are reported as their authors put them.

According to its supporters

  • The government argues that the top of the income distribution pays a lower effective rate than the middle, mainly because profits and dividends paid to individuals are exempt, and that a minimum tax restores progressivity.[3]
  • According to the explanatory memorandum, the relief mainly benefits lower-income workers, leaves them more income for priority needs and, through consumption, supports economic activity.[3]
  • The Ministry of Finance states that the measure has no net fiscal cost, since the loss of revenue is offset by higher taxation of about 140,000 high-income people, with no spending cut required.[7]
  • The government presents the ceiling on combined company and shareholder taxation (34%, 40% or 45%) as a safeguard against excessive taxation of profits that could discourage investment in Brazil.[3]

According to its opponents

  • In a dissenting opinion in the special committee, Deputy Gilson Marques (NOVO) questions the credibility of the offsetting revenue: borne by about 140,000 taxpayers, it is projected to grow each year, whereas in his view these taxpayers will adapt and the yield will fall.[5]
  • The same opinion argues that the R$ 50,000 monthly threshold, set in nominal terms, will be eroded by inflation and reach ever more people over time.[5]
  • According to the same opinion, the relief should be financed by cutting public spending and privileges rather than by raising more revenue.[5]
  • Experts heard by the committee and quoted in that opinion (a tax law professor at FGV, the commerce confederation CNC) argue that profits are already taxed at about 34% at company level and that the 10% withholding on dividends sent abroad creates legal uncertainty and a risk of capital flight.[5]

Indicators to watch

  • Gini index · Banque mondialeSee the card →
  • Tax revenue, % of GDP · Banque mondialeSee the card →
  • Direct taxes, % of GDP · OCDEno Citoyen card yet
  • Government revenue, % of GDP · OCDEno Citoyen card yet
  • Personal income tax revenue (IRPF) and minimum-tax revenue · Receita Federalno Citoyen card yet

Sources

  1. [1]Lei nº 15.270, de 26 de novembro de 2025 (texto atual) –Senado Federal / Câmara dos Deputados, normas.leg.br, November 26, 2025
  2. [2]PL 1087/2025: ficha de tramitação –Câmara dos Deputados
  3. [3]Projeto de Lei n. 1087/2025 e Exposição de Motivos EM nº 00019/2025 MF (inteiro teor) –Câmara dos Deputados / Ministério da Fazenda, March 18, 2025
  4. [4]Parecer do Relator n. 3 PL108725 (Dep. Arthur Lira), Comissão Especial sobre Alteração da Legislação do Imposto de Renda –Câmara dos Deputados, July 16, 2025
  5. [5]Voto em Separado n. 1 PL108725 (Dep. Gilson Marques) –Câmara dos Deputados, July 16, 2025
  6. [6]PL 1087/2025: processo legislativo no Senado Federal (dados abertos) –Senado Federal
  7. [7]Presidente sanciona lei que amplia isenção do Imposto de Renda para quem ganha até R$ 5 mil –Ministério da Fazenda, November 26, 2025
  8. [8]Receita Federal orienta fontes pagadoras e contribuintes a calcular a redução do imposto de renda a partir de 1º de janeiro de 2026 –Receita Federal do Brasil, December 11, 2025
  9. [9]Receita Federal lança Perguntas e Respostas sobre Tributação de Altas Rendas - Considerações sobre Lucros e Dividendos –Receita Federal do Brasil, December 16, 2025
  10. [10]Receita Federal atualiza normas relativas ao Imposto sobre a Renda das Pessoas Físicas (IN RFB nº 2299/2025) –Receita Federal do Brasil, December 18, 2025
  11. [11]STF recebe ações contra nova lei sobre tributação de dividendos e altas rendas –Supremo Tribunal Federal, December 24, 2025
  12. [12]STF prorroga prazo para aprovação de lucros e dividendos até 31 janeiro de 2026 –Supremo Tribunal Federal, December 26, 2025
  13. [13]ADI 7912: acompanhamento processual –Supremo Tribunal Federal