On Friday, December 26, 2025, Complementary Law No. 224/2025 (“LC 224”), derived from Complementary Bill No. 128/2025, was published. In general terms, this law reduces federal tax incentives and benefits by 10% and increases the Withholding Income Tax (IRF) rate on Interest on Equity Capital (JCP), as well as the Social Contribution on Net Profit (CSLL) rate for certain institutions in the financial sector.
With regard to tax incentives, LC 224 aims to reduce federal tax benefits by 10% while imposing stricter rules for their granting, extension, and renewal. These rules include, among others, a maximum duration of up to 5 years for such benefits, as well as mandatory outcome evaluation for these incentives.
The 10% reduction established by LC 224 directly affects several federal tax benefits, such as the presumed profit regime, the REIQ program, presumed credits for IPI and PIS/COFINS (including imports), as well as zero or reduced rates for the latter. Furthermore, the Annual Budget Law may list other tax benefits subject to this reduction.
However, certain tax benefits are excluded from this reduction. These include constitutional tax immunities, benefits related to the Manaus Free Trade Zone, zero tax rates for basic necessity products, incentives granted to non-profit organizations, and those linked to investments approved before December 31, 2025.
Specifically for the presumed profit regime, there will be a 10% increase in the presumption rates applied exclusively to the portion of gross revenue exceeding BRL 5,000,000 per calendar year. The tax administration stipulates that this increase will be calculated proportionally for each quarter and will apply to companies with quarterly revenues exceeding BRL 1,250,000.
Especificamente em relação ao lucro presumido, haverá acréscimo de 10% sobre os percentuais de presunção exclusivamente sobre a parcela da receita bruta que exceda R$ 5.000.000,00 no ano calendário. Considerando o regime trimestral de apuração aplicável a esse regime, a Receita Federal entende que o acréscimo de 10% deverá considerar a proporção por trimestre, sendo aplicável às empresas cuja receita bruta exceder R$ 1.250.000,00 por trimestre.
Additionally, LC 224 establishes that if tax incentives exceed 2% of the national GDP, no new programs may be granted or existing ones extended unless compensatory measures are adopted.
Finally, Complementary Law No. 224/25 will come into effect on January 1, 2026, except for tax measures subject to the 90-day precedence rule, which will take effect on April 1, 2026. Companies are strongly advised to evaluate and reassess their tax regimes to mitigate the financial impact of these new rules.
For further information on the subject, we remain at your disposal.
GTLawyers – Tax Team
On December 9th, we had the honor of attending the Year-End Dinner hosted by Belgalux – the Belgian-Luxembourg-Brazilian Chamber of Commerce and Industry. This event celebrated the strong connections between Belgium, Luxembourg, and Brazil, bringing together members of the diplomatic corps, associates, and strategic partners.
Our firm was represented by Cécile Verdeaux, Legal Director of Belgalux, along with Jeanne Puech and Tiago Carneiro Tavano. The evening was highlighted by inspiring moments, enriching speeches, and a warm celebration of the achievements that strengthened the ties between the countries throughout 2025.
A big thank you to Belgalux for the impeccable organization! We remain motivated to continue building bridges that connect Brazil, Belgium, and Luxembourg. Bring on 2026!
Last week, our partner, Estevão Gross, had the honor of participating in the Lunch-Debate organized by the France-Brazil Chamber of Commerce (CCIFB), alongside Bernard Appy, Extraordinary Secretary for Tax Reform at the Ministry of Finance. The event took place at the headquarters of Pernod Ricard in São Paulo and brought together representatives from member companies.
During the meeting, regulations and transition mechanisms for the new tax model were discussed. Secretary Appy shared his insights on the challenges and impacts of the Tax Reform, highlighting key points such as:
- The start of the transition in 2026, ensuring companies have sufficient time to adapt to the new model;
- The correction of distortions in the current tax system, promoting greater tax fairness and increasing the autonomy of states to strategically allocate resources;
- The implementation schedule, with a gradual transition planned until 2033, providing balance and adaptability throughout the process.
The debate offered critical insights for both Brazilian and French companies already preparing for this significant transformation. A special thanks to CCIFB-SP for organizing the event and to Pernod Ricard for hosting this important discussion!
Last week, we had the pleasure of assisting in the organization, alongside La Bienfaisance, of a very special end-of-year cocktail event at the French Consular Residence in São Paulo.
Representing our founding partner, Tamy Tanzilli, who also serves as the legal director of the association, the GTLawyers team—composed of Cécile Verdeaux and Jeanne Puech—was fully engaged in the organization of this significant event for us.
The gathering was honored by the presence of Alexandra Mias, Consul-General of France, who warmly welcomed us. Additionally, it was a unique opportunity to bring together friends, partners, volunteers, and donors who, through their support of La Bienfaisance, help transform lives.
For over 140 years, La Bienfaisance has been supporting French citizens in vulnerable situations in Brazil. With a presence in states such as São Paulo, Rio Grande do Sul, Santa Catarina, Paraná, and Mato Grosso do Sul, the association carries on the legacy of its founder, Jules Martin, by providing support and dignity to those who need it most. Driven by the voluntary efforts of professionals from a variety of fields, the association undertakes concrete actions, creates opportunities, and strengthens bonds of solidarity and fraternity.
Our heartfelt thanks go to the team at the General Consulate for opening its doors, as well as to the tireless support of all the friends, volunteers, and donors of La Bienfaisance. It is thanks to you that this mission remains alive and strong after all these years. May the values of solidarity and fraternity continue to unite us in this beautiful journey!
This weekend, we had the joy of organizing our Green Day, an event that brought our team together for a special initiative: planting 45 trees in Itu.
Beyond contributing to environmental preservation and building a sustainable future, "Green Day" was also an opportunity for the firm to come together. In a relaxed setting, we strengthened bonds and celebrated the unity that drives our team.
This gathering reinforced important values for all of us, such as collaboration, care, and building together, promoting both the well-being of our team and the practical application of the principles that guide our work.
Yesterday, at GTLawyers, we had the pleasure of contributing to the Salvation Army, an organization dedicated to supporting the most vulnerable communities.
To support this cause, we donated computers and cell phones, as well as organized an internal clothing donation campaign with the collaboration of our entire team.
We are grateful to the Salvation Army for allowing us to be part of this important mission, and to the entire GTLawyers team who mobilized to organize this initiative and contribute so generously.
Yesterday was the first-ever Pet Day at GTLawyers!
The team's pets came to visit us, bringing lightness, joy, and countless smiles to our day.
We’re already looking forward to repeating this initiative and continuing to promote a welcoming space for everyone – including our furry friends!
On September 10, GTLawyers, in partnership with French Tech São Paulo, will host a happy hour bringing together professionals from the technology and innovation ecosystem in São Paulo.
The event will take place at the Le Pain Quotidien Brasil venue, located in Jardins, and aims to create a space for exchange and connection between entrepreneurs, investors, legal market professionals, and representatives from emerging startups.
Data: 10 de setembro de 2025
Time: 7:00 PM to 11:00 PM
Location: Le Pain Quotidien, Alameda Lorena 1914 – Jardins, São Paulo
Participation is free, but registration is required, and spots are limited. Happy Hour | French Tech São Paulo | Câmara de Comércio França-Brasil
GTLawyers participated in the event "Legaltech & Venture Capital: Growth and Challenges in the Legal Sector" with our lawyers Paula Costa e Silva and Ana Paula Ruiz, organized by the Spanish Chamber of Commerce and its Legal Committee.
The event focused on the current landscape of the legal sector, highlighting the significant transformation driven by technological innovations and the growing relevance of legaltechs and specialized investors. Topics such as process automation, artificial intelligence applied to law, and investment trends in the legal ecosystem were discussed during the meeting.
We thank the Spanish Chamber of Commerce and its Legal Committee for the impeccable organization and for providing a valuable space for exchange and learning.
We are pleased to announce that Estevão Gross, a partner at our firm, will represent GTLawyers at an event promoted by the CCBC – Brazil-Canada Chamber of Commerce.
The central theme will be “The New Taxation: Impacts on International and National Business in Brazil”, a crucial debate to understand the effects of tax reform on the business environment.
Estevão will join a panel of renowned experts to share his insights and experience on the challenges and opportunities arising in this new legal and economic landscape.
We thank the CCBC for this excellent initiative and for the invitation!
