Complementary Law No. 224/2025: changes to tax incentives
16/01/2026ICMS/RJ: State Law No. 11,071/2025 increases the Temporary Budget Fund (FOT) rate starting from March 2026
22/01/2026HIGHLIGHTS
Complementary Law No. 224/2025 promotes adjustments to Presumed Profit
Complementary Law No. 224/2025, published on December 26, 2025, established limitations on the granting and extension of tax incentives within the scope of the Federal Government and promoted reductions in existing incentives, including in the Presumed Profit taxation regime.
Following the publication of this Law, Decree No. 12,808 was also published on December 29, 2025, as well as RFB Regulatory Instruction No. 2,305, dated December 31, 2025.
What changes in Presumed Profit
For companies under the Presumed Profit regime that earn more than BRL 5 million per year, the legislation determines a 10% increase in the presumption base. This increase applies exclusively to the portion of annual gross revenue that exceeds the aforementioned revenue limit.
- Service providers: the presumption base increases from 32% to 35.2%;
- Commerce/Industry/Transportation: the presumption base increases from 8% to 8.8%.
Check out the practical effects:
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Companies with revenues of up to BRL 5 million in the calendar year:
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Companies with revenues above BRL 5 million in the calendar year:
Total calculation basis for IRPJ (Corporate Income Tax) and CSLL (Social Contribution on Net Income): BRL 1,952,000.00. |
Important recommendations
- Companies that traditionally fall under the Presumed Profit regime should reevaluate this option for 2026;
- Even companies that have already informed the DPC of their choice of the Presumed Profit regime can still change it;
- We recommend that this analysis be carried out as soon as possible, as any change in regime will take effect as of January 2026.
Tax consulting
Domingues e Pinho Contadores offers support to help companies adapt to tax changes. Count on our team's expertise for guidance: dpc@dpc.com.br.
How can DPC help your company?
Domingues e Pinho Contadores has a specialized team ready to assist your company.
Contact us at dpc@dpc.com.br
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