contato@taxup.com.br   São Paulo · Rio de Janeiro · Brasília
PT EN
TOOL · LAW AS OF 18 JULY 2026 · Actual profit · Dividend withholding 10% · Repatriation

Brazil Effective Tax Burden
on profit you repatriate.

How much of your Brazilian profit actually reaches the parent company after IRPJ, CSLL and the 10% dividend withholding that took effect in 2026 — calculated on your own figures, with the statute behind every number.

Published · Updated · 8 min read

Until 2025, profit distributed by a Brazilian company to a shareholder abroad left the country exempt from withholding. That ended on 1 January 2026: Law 15,270/2025 inserted §4 into article 10 of Law 9,249/1995 and subjected dividends paid, credited, delivered, employed or remitted abroad to a 10% withholding tax, on the gross amount, with no exemption floor. For an inbound investor this changes the only number that ever mattered: what actually arrives. This calculator applies the objective parameters of the statute to your figures — the profit is yours to enter, never a benchmark published by the firm. It covers the actual-profit regime (lucro real), which is mandatory for most foreign-owned subsidiaries.

01

Calculate the burden on your Brazilian profit

Enter the annual taxable profit of the Brazilian entity and how much of the after-tax profit you intend to distribute abroad. The tool applies the statutory rates below and shows where each real goes.

02

Which rates apply, and where each one comes from

Four statutory parameters produce the result. Each is reproduced below with its article and the date the text was consulted, so the figure can be audited against the law rather than trusted on our word.

ParameterRateLegal basisStatus
IRPJ — corporate income tax15% on taxable profitLaw 9,249/1995, art. 3, caputVerified in primary source
IRPJ surtax10% on the excess over R$ 20,000 per month of the assessment period (R$ 240,000/year)Law 9,249/1995, art. 3, §1 (as amended by Law 9,430/1996)Verified in primary source
CSLL — social contribution on profit9% (general, non-financial entities)Law 7,689/1988, art. 3, IIIVerified in primary source
Withholding on dividends paid abroad10% on the gross amount, no exemption floorLaw 9,249/1995, art. 10, §4, added by Law 15,270/2025, in force from 01/01/2026Verified in primary source
Consolidated texts consulted at planalto.gov.br on 18 July 2026.

Why the surtax rarely changes the headline

The 10% surtax is cumulative with the 15% and applies only to the portion of profit above the allowance — it does not replace the basic rate. Because the allowance is R$ 240,000 a year, any entity with meaningful profit converges to the combined nominal load of 34%. Below that threshold the effective corporate rate falls: at exactly R$ 240,000 of profit it is 24%.

Why this tool covers only the actual-profit regime

The presumed-profit regime (lucro presumido) is deliberately out of scope, and for most readers of this page it is also unavailable. Beyond the revenue ceiling of R$ 78 million in the prior calendar year, Law 9,718/1998, art. 14, III, requires the actual-profit regime of any legal entity with profits, income or capital gains arising from abroad — a condition that captures a large share of foreign-owned subsidiaries regardless of size. Choosing a regime is an entity-level analysis, not a calculator output; the tax regime page sets out the test.

03

What the result does not include

The figure covers taxes on profit only. A real repatriation decision moves on items this tool deliberately does not model, because each depends on facts it does not collect:

  • Consumption and transaction taxesIBS, CBS, ICMS, ISS, PIS/COFINS and the IOF on the foreign-exchange leg of the remittance.
  • Payroll charges and social security contributions.
  • Transfer pricing adjustments under Law 14,596/2023, which can change the taxable profit itself — see transfer pricing and Pillar Two.
  • Interest on net equity (JCP), an alternative remuneration route whose withholding rose to 17.5% under Complementary Law 224/2025.
  • Tax incentives, loss carryforwards (capped at 30% of profit) and book-to-tax adjustments.
  • Double-taxation treaties. Law 15,270/2025 is silent on treaties, and the general rule of art. 98 of the Tax Code applies. In practice the Brazilian treaty network usually caps source taxation of dividends at 10% to 15%, so a treaty will rarely reduce the burden below the 10% domestic rate — but the specific promulgating decree must be checked case by case.
04

Three situations that change the answer

Profits accrued up to 2025 may still be exempt

Article 10, §5, I of Law 9,249/1995 preserves the old exemption for profits relating to results assessed up to calendar year 2025 whose distribution was approved by the competent corporate body by 31 December 2025, provided payment follows the terms originally approved. Two cautions: the approval must be a corporate resolution, not a mere management proposal; and while the statutory text applicable to non-residents sets no 2028 deadline, the Brazilian tax authority has published guidance stating that payment must occur by 2028. That divergence is a live litigation risk, and the conservative course is to observe 2028.

The excess-burden credit under article 10-A

Article 10-A of Law 9,249/1995 grants the shareholder abroad a credit where the effective rate on the company profit plus the 10 percentage points of withholding exceeds the sum of the nominal IRPJ and CSLL rates (34% in general; 40% for insurers and certain financial institutions; 45% for banks). The credit is not automatic: it depends on an election by the beneficiary, on a claim filed within the statutory window, and on Executive regulation. The firm has not confirmed a published regulation as of 18 July 2026, which is why this calculator does not apply the credit to any figure.

Pillar Two, if the group is in scope

Groups whose ultimate parent reported consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years fall within Law 15,079/2024, which implements a qualified domestic minimum top-up tax as an Adicional da CSLL, effective from 1 January 2025. Where the Brazilian effective rate falls below 15%, a top-up may be collected in Brazil — Brazil adopted the QDMTT only, with no income inclusion rule or undertaxed payments rule of its own. This calculator flags the question and does not quantify it: the GloBE tax base differs from the IRPJ/CSLL base, the test is jurisdiction-wide rather than entity-by-entity, and substance-based carve-outs and safe harbours require entity-level work. See OECD Pillar Two.

05

References and official sources

Repatriation review — free diagnostic

The TaxUp team reviews the actual position of the Brazilian entity before a distribution decision: effective rate, the impact of the 10% withholding, grandfathered profits and Pillar Two exposure.

Book a diagnostic
06

Frequently asked questions

How much tax does a Brazilian subsidiary pay on its profit?
On the actual-profit regime, 34% in combined nominal terms: IRPJ at 15%, a 10% surtax on the portion of annual profit above R$ 240,000, and CSLL at 9% for a general non-financial entity. The effective rate is lower for small profits because of the surtax allowance.
Are dividends paid from Brazil to a foreign shareholder taxed?
Yes, since 1 January 2026. Law 15,270/2025 added §4 to article 10 of Law 9,249/1995, subjecting profits and dividends paid, credited, delivered, employed or remitted abroad to a 10% withholding tax on the gross amount, with no exemption floor and no aggravated rate for low-tax jurisdictions. Until 2025 the remittance was exempt.
What is the total effective tax burden on profit repatriated from Brazil?
40.6% where the whole after-tax profit is distributed and the profit is well above the surtax allowance: 34% at the corporate level, then 10% withholding on the remaining 66%. Out of every R$ 100 of pre-tax Brazilian profit, R$ 59.40 reaches the foreign shareholder. The effective rate is lower for smaller profits, because the first R$ 240,000 a year is outside the 10% surtax.
Does keeping the profit in Brazil avoid the 10% withholding?
No — it defers it. The withholding applies whenever the profit is paid, credited, employed, delivered or remitted. Retention keeps the burden at the corporate level for the time being, and the marginal cost of repatriating later is up to 6.6 percentage points on the original profit — the calculator shows the exact figure for the amount entered.
Can a double-taxation treaty reduce the 10% withholding?
Rarely. Law 15,270/2025 is silent on treaties and the general rule of article 98 of the Tax Code applies, but the Brazilian treaty network typically caps source taxation of dividends between 10% and 15%. The practical effect therefore tends to be nil or marginal, and the applicable promulgating decree must be verified case by case.
Can my Brazilian entity use the presumed-profit regime instead?
Often it cannot. Beyond the R$ 78 million prior-year revenue ceiling, article 14, III of Law 9,718/1998 requires the actual-profit regime of any entity with profits, income or capital gains arising from abroad — a condition that captures many foreign-owned subsidiaries regardless of size.
TECHNICAL AUTHORSHIP

TaxUp Tax Practice

Brazilian Tax Law

Content produced by the TaxUp technical team and reviewed by a senior consultant before publication. Meet the firm →

Bring this analysis to your company’s case

30 minutes with a senior consultant. We map your specific tax scenario and point out the technical path forward — no obligation.

Book a diagnostic
Book a diagnostic