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FREE TOOL · LC 224/2025 · UPDATED 17 SEPTEMBER 2026 · IRPJ · CSLL · quarterly threshold · open calculation

Brazil LC 224 calculator.
What does presumed profit cost in 2026?

Enter quarterly revenue for each activity. The tool applies the old and new percentages, allocates the BRL 1.25 million threshold across the revenue mix, separates the ordinary 10% IRPJ surtax, starts the CSLL increase in Q2 and displays separate annual checks for the IRPJ and CSLL bases.

Published · Updated · 10 min read

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.

01

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.

02

The formula: 10% on the percentage, not on the tax rate

Common presumed percentages before and after LC 224. The legal classification of each revenue stream must be confirmed separately.
Original percentageLC 224 percentageExtra 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.

03

The Federal Revenue example: BRL 1.5 million in one quarter

FEDERAL REVENUE Q&A · QUESTION 11BRL 1.5m of commerce revenue in Q1BRL 1,250,000 × 8%original band = BRL 100,000 presumed baseBRL 250,000 × 8.8%BRL 22,000 presumed basePresumed base: BRL 122,000 · before LC 224: BRL 120,000
A visual reconstruction of the Federal Revenue Service example in question 11. Any later annual adjustment must be reconciled separately.

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.

04

How the threshold is allocated across activities

ActivityQuarterly revenueOriginal bandLC 224 excessBase calculation
CommerceBRL 1,440,000BRL 1,000,000BRL 440,0008% + 8.8%
ServicesBRL 360,000BRL 250,000BRL 110,00032% + 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.

05

IRPJ and CSLL start at different points in 2026

2026 EFFECTIVE-DATE TIMELINEIRPJQ1Q2Q3Q4CSLLno increaseQ2Q3Q4IRPJ annual threshold: BRL 5m · CSLL 2026 threshold: BRL 3.75m
Timing confirmed in questions 12 and 13 of Federal Revenue Q&A version 5.

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.

06

Amounts added in full to the bases do not consume the threshold

AmountCounts toward the BRL 5m threshold?Tax-base treatment
Revenue subject to a presumed percentageYesOriginal percentage within the band; LC 224 percentage on the excess
Amounts computed in full under the applicable rulesNoAdded 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.

07

The calculation starts the CFO decision; it does not finish it

Question after calculationWork requiredOwner
Is the local close correct?Reconcile activity classification, timing, threshold allocation and additionsController / tax compliance
Does presumed profit still make economic sense?Compare the same forecast under presumed and actual profitCFO / tax planning
Should the entity evaluate litigation?Measure exposure, evidence, current cases and procedural riskLegal / 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.

08

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 review
09

Frequently asked questions

Did LC 224 increase Brazil’s tax rate by 10%?
Not directly. Article 4, paragraph 4(VII) increases by 10% the percentages used to presume the tax base. Thus 8% becomes 8.8% and 32% becomes 35.2% on the affected revenue. The cash-tax effect depends on the activity, excess revenue, tax rates and the ordinary IRPJ surtax.
What quarterly threshold applies in 2026?
Federal Revenue guidance uses BRL 1.25 million per quarter. The original presumed percentage applies within that amount and the LC 224 percentage applies to the excess. Later-period adjustment is permitted, while the annual IRPJ threshold remains BRL 5 million.
Does the CSLL increase apply from Q1 2026?
No. Under Federal Revenue question 12, the IRPJ increase applies from Q1 and the CSLL increase from Q2. The effective 2026 CSLL threshold is therefore BRL 3.75 million.
How are two activities with different percentages calculated?
The quarterly threshold is allocated according to each activity’s share of total quarterly revenue. Each activity’s original band and excess then receive its own original and increased percentages. Federal Revenue question 14 provides the commerce-and-services example.
Does financial income count toward the BRL 5 million threshold?
Not when, in the specific case, the amount is computed in full in the tax base rather than subjected to a presumed percentage. Question 11.1 separates those amounts from the threshold test. Income subject to exclusive taxation or a specific regime requires its own treatment.
Is this the same as the ordinary 10% IRPJ surtax?
No. The ordinary IRPJ surtax applies to the part of the quarterly IRPJ base above BRL 60,000. LC 224 operates earlier by changing the percentage that forms the presumed base. The calculator displays the two effects separately.
Can every foreign-owned Brazilian subsidiary use presumed profit?
No. Foreign ownership alone is not the legal test, but the entity must satisfy the revenue ceiling and avoid the statutory situations that make actual profit mandatory. Eligibility must be checked for the specific Brazilian entity before using the calculator for a filed position.
Does this calculator replace the Brazilian tax return or close workpaper?
No. It is a transparent estimate for budgeting and review. The actual close must validate the nature of each revenue stream, applicable percentage, full-base additions, timing, annual adjustments and accounting records.
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