This tool applies article 4, paragraphs 4(VII) and 5 of LC 224/2025 and questions 11–14 of the Federal Revenue Service’s Q&A, version 5. Only revenue subject to presumed percentages enters the BRL 5 million test. A separate input is available for amounts that, in the specific case, are added in full to both the IRPJ and CSLL bases. The tax increase displayed is provisional and does not incorporate the tax effect of the annual base checks. The output supports budgeting and control review; it is not a filed tax computation or an entity-specific legal conclusion.
Calculate the 2026 impact quarter by quarter
| Activity | IRPJ % presumption |
CSLL % presumption |
Q1 (BRL) | Q2 (BRL) | Q3 (BRL) | Q4 (BRL) |
|---|---|---|---|---|---|---|
| Amounts added in full to both the IRPJ and CSLL bases in this case (excluded from the BRL 5m threshold) | ||||||
The result is an estimate based on the figures entered. It applies the BRL 1.25 million quarterly threshold, allocates it by activity, starts the CSLL increase in Q2 2026, separates the ordinary 10% IRPJ surcharge and displays the later IRPJ and CSLL base reconciliations separately. It does not decide whether litigation or a tax-regime change is appropriate.
Use one row for each activity that has its own presumed percentage. The presets are operational shortcuts, not a legal classification of your revenue. Confirm the activity treatment before closing the return. Use the final row only for amounts that are added in full to both the IRPJ and CSLL bases in the specific case. Amounts subject to exclusive taxation, a specific regime or different treatment between the two bases require a separate workpaper.
The formula: 10% on the percentage, not on the tax rate
| Original percentage | LC 224 percentage | Extra presumed base per BRL 100,000 of excess revenue |
|---|---|---|
| 1.6% | 1.76% | BRL 160 |
| 8% | 8.8% | BRL 800 |
| 12% | 13.2% | BRL 1,200 |
| 16% | 17.6% | BRL 1,600 |
| 32% | 35.2% | BRL 3,200 |
Article 4, paragraph 4(VII) requires a 10% increase in the presumed percentages. The object of the change is the percentage used to form the tax base, not the IRPJ or CSLL rate. Therefore, 8% × 1.10 is 8.8%, 12% becomes 13.2% and 32% becomes 35.2%.
Once the base is formed, the ordinary rates remain: generally 15% IRPJ, the separate 10% IRPJ surtax on the quarterly base above BRL 60,000, and 9% CSLL. The calculator follows that order.
The Federal Revenue example: BRL 1.5 million in one quarter
Question 11 uses a commerce company with BRL 1.5 million of revenue in Q1 2026. The IRPJ base is 8% on BRL 1.25 million plus 8.8% on the BRL 250,000 excess. The presumed base rises from BRL 120,000 to BRL 122,000.
In that example the provisional IRPJ difference is BRL 500: BRL 300 at the 15% rate and BRL 200 under the ordinary 10% surtax, because the base already exceeds BRL 60,000. The LC 224 increase does not yet apply to CSLL in Q1 2026.
How the threshold is allocated across activities
| Activity | Quarterly revenue | Original band | LC 224 excess | Base calculation |
|---|---|---|---|---|
| Commerce | BRL 1,440,000 | BRL 1,000,000 | BRL 440,000 | 8% + 8.8% |
| Services | BRL 360,000 | BRL 250,000 | BRL 110,000 | 32% + 35.2% |
Question 14 prevents a company from choosing which activity consumes the non-increased band. The quarterly threshold is allocated in proportion to the revenue mix.
In the official example, total quarterly revenue is BRL 1.8 million: BRL 1.44 million, or 80%, from commerce and BRL 360,000, or 20%, from services. The BRL 1.25 million threshold is therefore divided into BRL 1 million for commerce and BRL 250,000 for services. The respective excesses are BRL 440,000 and BRL 110,000.
The ERP and close workpaper must preserve revenue by activity. Applying one percentage to total revenue can misstate both the original band and the increased band.
IRPJ and CSLL start at different points in 2026
Federal Revenue question 12 applies the increased IRPJ percentages from Q1 2026. For CSLL, the change begins in Q2 after the 90-day constitutional waiting period. The 2026 CSLL threshold is therefore BRL 3.75 million, covering the three affected quarters.
LC 224 permits adjustments in later assessment periods of the same year. The tool shows the annual IRPJ presumed-base check and the annual CSLL presumed-base check separately. The tax increase displayed above is provisional and does not incorporate the tax effect of those adjustments, because that effect depends on the period in which each adjustment is booked and, for IRPJ, may also depend on the ordinary surtax.
Amounts added in full to the bases do not consume the threshold
| Amount | Counts toward the BRL 5m threshold? | Tax-base treatment |
|---|---|---|
| Revenue subject to a presumed percentage | Yes | Original percentage within the band; LC 224 percentage on the excess |
| Amounts computed in full under the applicable rules | No | Added to the relevant IRPJ and/or CSLL base |
Question 11.1 separates the threshold test from the final taxable base. Revenue and results computed in full — such as financial income and capital gains subject to the general rule — do not consume the threshold. Amounts subject to exclusive taxation or a specific regime require their own treatment.
They are not automatically exempt. The calculator’s separate row should be used only when the same amount is added in full to both the IRPJ and CSLL bases in the specific case. Differences between the two bases require a separate workpaper.
The calculation starts the CFO decision; it does not finish it
| Question after calculation | Work required | Owner |
|---|---|---|
| Is the local close correct? | Reconcile activity classification, timing, threshold allocation and additions | Controller / tax compliance |
| Does presumed profit still make economic sense? | Compare the same forecast under presumed and actual profit | CFO / tax planning |
| Should the entity evaluate litigation? | Measure exposure, evidence, current cases and procedural risk | Legal / tax director |
A positive difference leads to three separate workstreams. Operationally, the close and ERP must apply the correct threshold, date and activity allocation. Economically, the group should test whether the new burden and actual margin still support presumed profit or justify modeling actual profit. Legally, the entity may assess whether its facts, evidence and risk appetite support the LC 224 controversy.
Foreign ownership by itself neither grants nor removes eligibility for presumed profit. The Brazilian entity must be tested against the revenue ceiling and mandatory actual-profit situations under local law. The Brazilian tax-regime guide covers that entity-level choice.
For current cases, use the LC 224 litigation tracker. The calculator supplies a common workpaper so finance, accounting and legal teams discuss the same amount; it does not recommend a court filing or a regime change.
References and official sources
Turn the estimate into a close-ready tax model
The TaxUp team validates revenue classification, reconciles all four quarters and compares presumed and actual profit using the Brazilian entity’s own data.
Request a tax model reviewFrequently asked questions
Did LC 224 increase Brazil’s tax rate by 10%?
What quarterly threshold applies in 2026?
Does the CSLL increase apply from Q1 2026?
How are two activities with different percentages calculated?
Does financial income count toward the BRL 5 million threshold?
Is this the same as the ordinary 10% IRPJ surtax?
Can every foreign-owned Brazilian subsidiary use presumed profit?
Does this calculator replace the Brazilian tax return or close workpaper?
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