On November 26, 2025, Bill 1,087/2025 was signed into law by the President of the Republic, becoming Law 15,270/2025, with effect as of January 1, 2026. The new law significantly reshapes the taxation of individual income, introducing, among other measures, the Minimum Individual Income Tax (IRPFM) and a 10% withholding tax on dividends paid to Brazilian individual taxpayers and to foreign investors.
The bill was enacted without vetoes, meaning that all provisions approved by Congress were maintained, including the rules conditioning the exemption of dividends accrued up to the 2025 calendar year on a corporate resolution approving their distribution by December 31, 2025, as well as the related formal requirements.
In parallel, there remains an expectation that, before the end of the legislative recess, a regulation stemming from Bill 5,473/2025 — currently under discussion in the Senate’s Economic Affairs Committee — will be approved, with the aim of adjusting specific aspects of Law 15,270/2025, including rules on tax credit utilization, tax-burden calibration, and transition measures related to the distribution of accumulated profits.
Our recommendation is that taxpayers urgently prepare for this scenario, including:
- taking the necessary steps to resolve, still in 2025, the distribution of accumulated profits and reviewing their corporate structures so as to properly benefit from the transition regime and reduce exposure to the new dividend taxation and to the minimum individual income tax as of 2026;
- preparing a detailed assessment and calculations of the law’s actual impact as enacted, based on their specific circumstances (income profile, corporate structure, level of profit distributions in Brazil and abroad, etc.); and
- preparing an initial adoption report with a set of concrete actions to mitigate the future effects of the new tax rules, including redesigning dividend policies, reviewing investment structures, and analyzing opportunities for corporate reorganization.
Our Tax team is available to support the evaluation of the impacts of Law 15,270/2025, the development of mitigation strategies, the necessary calculations, and the implementation of appropriate measures in each case.
Click here to access the material prepared by our team on the former Bill 1,087/2025—now enacted into law—as well as new content that will be updated in light of the presidential sanction.