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Corporate income tax in Brazil: IRPJ and CSLL

Last verified: 2026-10-25

Brazilian companies pay two federal taxes on profit: IRPJ at 15% plus a 10% surcharge on profit above BRL 20,000 a month, and CSLL, normally 9%. The combined headline rate for a non-financial company is 34%; banks and other financial institutions pay higher CSLL rates, some of which rose from April 2026. Companies choose between actual profit (lucro real) and presumed profit (lucro presumido), which is only available below BRL 78 million of prior year revenue.

The rule

1. IRPJ is levied at 15% of taxable profit.Law 9,249/1995, art. 3, caput, 1995-12-26 official text
2. A 10% IRPJ surcharge (adicional) applies to the portion of actual, presumed or arbitrated profit that exceeds BRL 20,000 multiplied by the number of months in the period, so BRL 240,000 for a full year. The surcharge cannot be reduced by deductions.Law 9,249/1995, as amended by Law 9,430/1996, art. 3, paras. 1 and 4, 1996-12-27 official text
3. CSLL is 9% for companies in general. It is 15% for private insurers and several categories of financial institutions listed in LC 105/2001, and 20% for banks (LC 105/2001, art. 1, para. 1, item I).Law 7,689/1988, as amended by LC 224/2025, art. 3, items I, II-A and III, 2025-12-26 official text
4. LC 224/2025 created new CSLL tiers: payment institutions and certain market infrastructure entities pay 12% until 31 December 2027 and 15% from 1 January 2028; credit, financing and investment companies (SCFI) and capitalization companies pay 17.5% until 31 December 2027 and 20% from 1 January 2028. These changes take effect from the first day of the fourth month after publication, which was 1 April 2026.Complementary Law 224/2025, arts. 7 and 14, item I, b, 2025-12-26 official text
5. Companies with total revenue above BRL 78 million in the prior year, and banks, insurers and similar financial entities, must use actual profit (lucro real).Law 9,718/1998; Decree 9,580/2018 (RIR), Law 9,718 art. 14; RIR art. 257, 1998-11-27 official text
6. Companies with prior year revenue up to BRL 78 million (or BRL 6.5 million times months of activity) may elect presumed profit.Law 9,718/1998, art. 13, 1998-11-27 official text
7. Presumed profit for IRPJ is 8% of gross revenue in general, 1.6% for fuel resale, 16% for some transport, and 32% for services in general, brokerage, leasing of assets and factoring.Law 9,249/1995, art. 15, 1995-12-26 official text
8. Presumed base for CSLL is 12% of gross revenue in general and 32% for the service activities listed in art. 15, para. 1, item III.Law 9,249/1995, as amended by LC 167/2019, art. 20, 1995-12-26 official text
9. From 2026, LC 224/2025 raises presumption percentages by 10% (for example 32% becomes 35.2%) but only on the part of annual gross revenue that exceeds BRL 5 million. Contributions subject to the 90 day rule, such as CSLL, follow the April 2026 start date.Complementary Law 224/2025, art. 4, para. 4, VII and para. 5; art. 14, 2025-12-26 official text

Worked example

Actual profit company, taxable profit of BRL 10,000,000 in 2026 (about USD 1,985,033). IRPJ 15%: BRL 1,500,000. Surcharge 10% on BRL 9,760,000 (profit above BRL 240,000): BRL 976,000. CSLL 9%: BRL 900,000. Total BRL 3,376,000 (about USD 670,147), an effective 33.76%. Presumed profit comparison: a service company with BRL 4,000,000 of revenue (below the BRL 5 million LC 224 threshold) has a presumed base of 32%, BRL 1,280,000. IRPJ 15% is BRL 192,000, the surcharge is BRL 104,000 and CSLL 9% is BRL 115,200, a total of BRL 411,200 (about USD 81,625), or 10.28% of revenue. PIS and COFINS are separate. USD at the BCB PTAX selling rate of 23 October 2026, BRL 5.0377 per USD.

Step by step

  1. Model both regimes before the first payment of the year: under Law 9,430/1996 art. 26 the presumed profit option is made with the first payment for the first period of the year and covers the whole calendar year.
  2. Check whether the business falls into a mandatory actual profit category (revenue above BRL 78 million, financial activities, foreign source profits and others listed in RIR art. 257).
  3. If the company is financial or a payment institution, confirm its CSLL tier under the new art. 3 of Law 7,689/1988.
  4. For presumed profit companies with revenue above BRL 5 million, apply the LC 224/2025 uplift only to the excess revenue, allocated proportionally by activity.
  5. Calendar the monthly estimate or quarterly payments and the annual ECF filing with the Receita Federal.

Common traps

  • Quoting 34% as the rate for a fintech or bank: CSLL for those entities is now 12% to 20% depending on type.
  • Assuming presumed profit is always cheaper: margins below the presumed percentage make actual profit more efficient, and losses cannot be used under presumed profit.
  • Forgetting that the surcharge threshold is pro rated by month, so a short first year has a lower threshold.
  • Ignoring that the LC 224 uplift to presumed percentages is a 10% increase of the percentage itself, not 10 percentage points.

Sources

Related pages

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