Law No. 15,270/2025 Published – Taxation of Dividends
19/12/2025
Law No. 15.270/2025, resulting from the approval of Bill No. 1.087, was published on November 27, 2025. The main provisions of the Law, which will take effect as of January 1, 2026, are as follows:
Dividend Taxation and High-Income Taxation:
- Taxation of dividends received by individuals residing in Brazil at a 10% rate, when the amount exceeds BRL 50,000 per month from the same company.
- Taxation of dividends remitted to individuals or entities residing or domiciled abroad at a 10% rate.
- Taxpayers with annual income exceeding BRL 600,000 will be subject to a minimum tax with progressive rates that may reach up to 10%.
Important Notes:
- Profits accrued up to the year 2025 may be exempt from taxation if distributed until December 31, 2025; Payments can be made until 2028.
- The sum of the effective corporate income tax rate paid by the company distributing dividends and its shareholder cannot exceed 34%. Therefore, a reduction on the 10% dividend tax may be available depending on the company’s effective tax rate.
It is therefore advisable for companies to assess the existence of accumulated profits and consider distribution, in accordance with the law, to avoid additional taxation.
How to Prepare for 2026
With dividend taxation scheduled for 2026, it is essential for taxpayers and companies to evaluate tax optimization strategies, such as:
- Challenge of the dividend tax on distribution to non-Brazilian shareholders located in countries that signed a double tax treaty with Brazil.
- Tax deferral structures.
- Review of the company’s capital structure (debt instruments as opposed to the payment of dividends).
- Corporate reorganizations aimed at optimizing cash flow and mitigating future impacts.
The Tax Law team at Souto Correa Advogados is available to clarify any questions related to this matter.