On June 11, 2025, the Federal Government published Provisional Measure No. 1,303 (“PM 1,303”), which establishes new tax rules for: (i) financial investments, (ii) net gains from stock exchange transactions, (iii) virtual assets, (iv) securities lending, (v) investment funds, (vi) incentivized securities, and (vii) non-resident investors. Read more here.
PM 1,303 also changes certain tax rules applicable to legal entities, including increases in (i) the Social Contribution on Net Profit (“CSLL”) rates for certain financial institutions and other entities regulated and supervised by the Central Bank of Brazil, and (ii) the Withholding Income Tax (“WHT”) rate applied to the distribution of interest on equity (“JCP”). The tax burden on fixed-odds betting activities (BETs) was also increased. Access the full content.
Additionally, PM 1,303 modifies the rules for the offsetting of tax credits. Please see these changes by clicking here.
According to the explanatory memorandum, PM No. 1,303 aims to equalize the tax rates applied to financial market transactions. Furthermore, certain changes to the tax legislation introduced by PM 1,303 are expected to increase revenue collection by the Federal Government, which could neutralize the reduction in the tax collection resulting from the changes to the Tax on Financial Transactions (“IOF”) introduced by Decree No. 12,499, published on the same date. Check out the analysis of the recently enacted IOF decree.
PM 1,303 will come into effect on January 1, 2026 (subject to conversion into law), except for the increase in the CSLL rate and the higher tax burden on fixed-odds betting activities, which will come into effect on October 1st, 2025.
Want to understand what changes in practice? Access the full material.
Among the highlights, the guide details:
- A unified 17.5% income tax rate for financial investments under the general regime and the possibility of offsetting losses;
- Specific taxation rules for virtual assets;
- Taxation of investment funds;
- Taxation of incentivized securities;
- Tax regime applicable to non-resident investors;
- Possibility of deducting losses from hedge contracts abroad;
- Limitation of tax credit offsetting rules;
- Increase in the WHT rate on JCP; and
- Increase in the CSLL rate for certain legal entities.
The material was prepared based on the analysis of our Tax Practice. Access the full content now and understand all the impacts of PM 1.303.
