Brazil enacts law on taxation of dividends

On November 26, 2025, the Brazilian President approved the final version of Bill No. 1,087/2025, converting it into Law No. 15,270/2025 (published in the Official Gazette on November 27). The enacted law introduces new rules for minimum taxation of income and withholding taxation of profits and dividends.

The Brazilian government originally introduced Bill No. 1,087/2025 in the House of Representatives in March this year. After eventually being subjected to certain amendments in the Senate, the bill was unanimously approved in both houses.

When it was introduced, the government’s bill raised several important issues for taxpayers. Despite certain amendments being submitted in an attempt to address this, they were not included in the approved law. Given that both Congress and the President ultimately upheld the majority of the original bill’s provisions, taxpayers will need to pay close attention to such issues. This previously published article examines the key aspects of the approved bill, as well as certain controversies surrounding the new rules.

Law No. 15,270/2025 is set to take effect as of January 1, 2026. However, certain aspects will require immediate attention from taxpayers – especially those who seek to benefit from the withholding income tax exemption applicable to profits and dividends relating to results determined up to the end of 2025, whose distributions are approved by year-end.

For more information about this topic and potential related disputes, please contact Mattos Filho’s Private Client and Tax practice areas.