Brazil’s new dividend withholding tax (WHT) has been in force for nearly a month, but questions remain about its application. The December 16, 2025 Q&A confirms that dividends paid to foreign governments, sovereign funds and social‑security‑benefit managers are exempt, and that the exemption also covers entities wholly owned by exempt investors. However, in structures where a Brazilian entity is held by a foreign holding company only partially owned by exempt investors, the exemption may not apply, potentially subjecting dividends to full WHT.
It states that dividends paid to foreign governments, sovereign funds and entities managing social security benefits are exempt from WHT under Art. 10, §5, II of Law No. 9,249.
Yes, the exemption also applies when dividends are paid to entities that are wholly owned, directly or indirectly, by exempt investors.
No, the exemption would not apply, and dividends to the foreign holding could be fully subject to WHT, as the exempt investor does not indirectly own 100% of the Brazilian entity.
The author suggests that the tax authorities clarify that the exemption should apply proportionally based on the exempt investor’s indirect ownership.
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VatCalc · 12 days ago
Brazil’s 2026‑2032 VAT reform introduces a targeted “Cashback” mechanism that refunds part of the new CBS and IBS taxes to low‑income families. The scheme will reimburse 100% of CBS and 20% of IBS on essential utilities (draft figures) and is expected to start in 2027 with a phased rollout. Refunds will be transferred electronically to families’ bank accounts linked to their CPF.
Sovos · 18 days ago
Complementary Law No. 227/2026, published on 13 January 2026, formally establishes the Management Committee of the Goods and Services Tax (CGIBS) and sets out governance, litigation, and revenue distribution rules for Brazil’s new IBS tax. The law does not impose immediate obligations on taxpayers but signals a shift to a centralized, standardized administration that will affect audits, enforcement, and data cross‑checking in the future.
Sovos · 19 days ago
The Brazilian Federal Government will reduce tax incentives for several federal taxes starting in 2026. Corporate Income Tax and Import Tax incentives will be cut from 1 January 2026, while other taxes such as PIS/Pasep, Cofins, CSLL, IPI, and employer social security contributions will see reductions from 1 April 2026. The changes affect a broad range of tax regimes and are subject to complementary legislation.
VatCalc · 25 days ago
Brazil has approved a second law that operationalises its dual VAT system, introducing a federal CBS tax of 8.8% and a state/municipal IBS tax of 17.7% and replacing PIS, Cofins, ICMS and ISS. The legislation establishes a national governance body for IBS, provides sector‑specific rules, and sets a phased transition from 2026 to 2033.
VatCalc · 28 days ago
Brazil is launching a seven‑year transition to a dual VAT system, replacing PIS, Cofins, ICMS and ISS with federal CBS and state IBS. The pilot starts in 2026 with minimal rates and e‑invoicing waivers, while full implementation is slated for 2033 with a consolidated rate of roughly 28%. The reform includes compensation funds for states and a shift to a destination‑based regime.
iGamingBusiness · about 16 hours ago
Colombia’s Constitutional Court suspended the emergency decree that imposed a 19% VAT on online gambling, leaving operators subject only to the standard 15% GGR tax. The suspension, effective from 29 January 2026, will remain until the court’s plenary chamber issues a final decision. The 19% VAT, originally introduced in February 2025 on deposits, expired on 31 December 2025 before being shifted to GGR.
