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Legislation library · IRPJ and CSLL

IRPJ and CSLL legislation: the rules, their status and the source

37 rules on corporate income tax (IRPJ) and the social contribution on net income (CSLL): actual profit (lucro real), presumed profit (lucro presumido) and deemed profit (lucro arbitrado), interest on equity, offsets, subsidies and the effect of the consumption tax reform.

Assessment for each period in SAP is covered in IRPJ and CSLL assessment in SAP, and bookkeeping in ECD and ECF in SAP.

Versão em português
Index

Where to start, based on your role

People who read these rules look for different things.

01Tax and accounting

Which regime applies, which adjustments enter the actual profit and which article supports each point.

Go to the section

02IT and SAP

In SAP, each adjustment must keep its reason, period, control balance and revenue by activity.

Go to the section

03Management and decisions

The new presumed profit percentages, the withholding on interest and the subsidy credit, with dates.

Go to the section

04Audit and control

Which rules are in force, which were replaced and where the official text is.

Go to the section
Direct links
Highlights

What to watch now

Six points with dates, from the changes in LC 224 in 2026 to the treatment of losses in 2027.

2026

New presumed profit percentages

LC 224 adds 10% to the presumption percentages on the part of revenue above BRL 5,000,000.00 in the year. See the entry

2026

17.5% withholding on interest

Article 8 of LC 224 changes the withholding on interest on equity. See the entry

2028

CSLL for financial institutions

Different rates until 31/12/2027 and from 01/01/2028 for some institutions. See the entry

2024

Subsidy tax credit

Law 14.789 replaces article 30 of Law 12.973 from January 1, 2024. See the entry

2027

Credit losses

LC 214 points to the income tax deductibility rules for periods starting on or after 01/01/2027. See the entry

17/09/2026

IN 2.343 amends IN 1.700

The instruction changed the treatment of hospital services under presumed profit and of financial institutions. See the entry

Regimes and rates

Regimes and rates side by side

The table shows how the law treats each regime and each contribution. Which one applies to your company is your decision.

CasePeriod or formRate or percentageLegal basis
Actual profitQuarterly, or annual with monthly estimatesIRPJ 15% plus a 10% surtax; CSLL under Law 7.689Law 9.430, arts. 1 and 2; Law 9.249, art. 3
Actual profit, mandatoryRevenue above BRL 78,000,000.00 and the other cases in art. 257Same ratesRIR, art. 257
Presumed profitQuarterly8%, 1.6%, 16% or 32% of revenue, depending on the activityLaw 9.249, art. 15; Law 9.430, arts. 25 and 26
Presumed profit, revenue above BRL 5,000,000.00QuarterlyPercentages increased by 10% on the excess portionLC 224, art. 4, §§ 4 and 5
Deemed profitQuarterlyPresumed profit percentages increased by 20%Law 9.249, art. 16; Law 8.981, art. 47
CSLL, general baseFollows the IRPJ payment method9% for other legal entitiesLaw 7.689, art. 3, III
CSLL under presumed profit and monthly estimatesPercentage of revenue12%, 32% or 38.4%, depending on the revenueLaw 9.249, art. 20
Financial institutions and insuranceAs set by lawSpecific CSLL ratesLaw 7.689, art. 3, with LC 224, art. 7
JCP, withholdingOn payment or credit17.5% tax withheldLaw 9.249, art. 9, § 2, with LC 224, art. 8
Tax loss and negative CSLL baseOffsetLimit of 30% of adjusted profitLaw 9.065, arts. 15 and 16
How they connect

How the rules connect

From the decree-law of 1977 to the instruction of 2026, by way of the consumption reform.

The decree-law defines, the laws detail

Decree-Law 1.598 defines actual profit and gross revenue. Laws 9.249 and 9.430 set rates, percentages, quarters and monthly estimates, and Law 12.973 rewrites points in all of them.

CSLL moves alongside

Law 9.430, art. 28, applies the income tax rules to CSLL. The base and the rate, however, come from Law 7.689 and Law 9.249.

The regulation brings it together

RIR/2018 gathers the content in one text up to 2016. IN 1.700 turns the laws into procedure and is amended often.

Incentives became credits

The old rule of exclusion into a reserve ended in 2024 and gave way to the credit in Law 14.789, with qualification, assessment in the ECF and offset.

LC 224 changes percentages and withholdings

It raises the presumed profit percentages above BRL 5,000,000.00, changes the withholding on interest and the CSLL rates of financial institutions.

The consumption reform changes the revenue base

IBS and CBS coexist with IRPJ and CSLL, and LC 214 has only specific rules on the two, by amending other laws.

Adjustments and offsets

From net profit to the tax, step by step

The steps the law provides between the accounting result and the amount to pay, with the legal basis in the last column.

StepWhat it isNoteLegal basis
Net profitStarting point of the actual profitFollows commercial lawDL 1.598, art. 6, § 1
AdditionsNon-deductible expenses and income not bookedE.g. prohibited provisions and giftsDL 1.598, art. 6, § 2; Law 9.249, art. 13
ExclusionsAuthorized amounts not yet countedPlus non-taxable resultsDL 1.598, art. 6, § 3
Loss offsetLosses from earlier periodsUp to 30% of adjusted profitLaw 9.065, art. 15
Negative CSLL baseSame rule, applied to CSLLUp to 30% of adjusted resultLaw 9.065, art. 16
Monthly estimateRevenue times percentageBalance determined on 31/12Law 9.430, art. 2
Investment subsidySubsidy revenue times 25%Outside the monthly estimateLaw 14.789, arts. 6 and 8
Tax incentive reserveOutside the base for interestReserve under art. 195-A of Law 6.404Law 9.249, art. 9, § 8
Offset against debtsDeclaration to the Revenue ServiceFive years for approvalLaw 9.430, art. 74
Subsidy creditOffset or reimbursementReimbursement in the 24th monthLaw 14.789, arts. 9 and 10
Taxes in revenueMere depositaryNot part of gross revenueDL 1.598, art. 12, § 4
Calendar

Deadlines and milestones for IRPJ and CSLL

Payment deadlines follow Law 9.430. The 2026 and 2027 milestones come from the two complementary laws.

Last business day

Quarter

Quarterly IRPJ is due by the last business day of the month after the quarter, in one payment, or in up to three monthly installments (Law 9.430, art. 5).

Last business day

Estimate

The monthly estimate is due on the last business day of the following month (Law 9.430, art. 6).

January

Option

The option for monthly estimates is made with the January payment and covers the whole year (Law 9.430, art. 3).

First installment

Presumed profit

The option for presumed profit is made with payment of the first or only installment of the year (Law 9.430, art. 26).

March 31

Annual balance

The positive balance of the 31 December adjustment is due on the last business day of March, with interest (Law 9.430, art. 6, § 1).

01/01/2026

LC 224

General provisions of LC 224 take effect on January 1, 2026 (art. 14, III).

01/04/2026

90-day wait

Provisions of art. 14, I, in force since the first day of the fourth month after publication (arts. 7 and 9).

01/01/2027

Losses

Date cited by LC 214 for the deductibility rules on credit losses.

Timeline

From 1977 to 2026, date by date

From the decree-law that defines actual profit to the normative instruction amended in September 2026.

DateWhat changedRule
26/12/1977Decree-Law 1.598 defines actual profit and gross revenueDecree-Law 1.598/1977
15/12/1988Law 7.689 creates CSLLLaw 7.689/1988
20/01/1995Law 8.981 brings rules on deemed profit and loss offsetLaw 8.981/1995
20/06/1995Law 9.065 sets the 30% limit on offsetsLaw 9.065/1995
26/12/1995Law 9.249 brings rates, presumed profit percentages, JCP and dividendsLaw 9.249/1995
27/12/1996Law 9.430 creates the quarter and the monthly estimateLaw 9.430/1996
13/05/2014Law 12.973 rewrites points of the taxLaw 12.973/2014
14/03/2017IN RFB 1.700 regulates IRPJ and CSLLIN RFB 1.700/2017
07/08/2017LC 160 treats ICMS benefits as subsidiesLC 160/2017
22/11/2018Decree 9.580 approves the RIR/2018Decree 9.580/2018
29/12/2023Law 14.789 creates the subsidy creditLaw 14.789/2023
16/01/2025LC 214 creates IBS and CBS and amends other lawsLC 214/2025
26/12/2025LC 224 cuts benefits and changes withholdingsLC 224/2025
18/03/2026IN 2.315 repeals items of art. 30 of IN 1.700IN RFB 2.315/2026
17/09/2026IN 2.343 amends IN 1.700IN RFB 2.343/2026
Library

The rules, by topic

37 rules in nine groups, from the Decree-Law of 1977 to the normative instruction of 2026.

In forcerule in force, with no caveat
With a caveatvalid on a condition: an end date, an effective date or a pending complementary act
Replacedanother rule took its place

Actual profit and calculation base6 rules

What actual profit is, where it starts, what enters gross revenue and what the law prohibits deducting.

In force

Decree-Law 1.598/1977, arts. 6 and 7: actual profit and bookkeeping

What it regulates

Article 6 defines actual profit as the net profit of the year with the addition, exclusion and offset adjustments that tax law prescribes or authorizes. Paragraph 2 requires adding back what was deducted in net profit and tax law does not accept as a deduction, and paragraph 3 allows excluding what the law authorizes and has not yet been counted.

Paragraph 4 deals with an amount that belongs to another period: it is recognized in the right period, in the opposite way. Article 7 says actual profit is determined from bookkeeping kept in line with commercial and tax laws.

Status
In force in 2026, with the current wording compiled by the Planalto (Presidency of Brazil) site.
Point to watch in SAP
Each adjustment needs a recorded reason, a period and a control balance when the effect spans periods.

IRPJ and CSLL assessment in SAP

In force

Decree-Law 1.598/1977, art. 12: gross revenue and net revenue

What it regulates
Gross revenue covers the sale of goods on own account, the price of services in general, the result of operations on behalf of others and revenue from the main activity not covered by the earlier items. Net revenue is gross revenue less returns and cancelled sales, unconditional discounts, taxes charged on it and the present value adjustment of linked operations. Gross revenue does not include non-cumulative taxes charged separately to the buyer by the seller as a mere depositary (§ 4).
Status
In force in 2026. It is the definition that presumed profit, the monthly estimate and deemed profit use as a base.
Point to watch in SAP
Gross revenue from each document must reach the assessment split by activity, with the deductions in art. 12, § 1, identified.

IRPJ and CSLL assessment in SAP

With a caveat

Law 12.973/2014: end of the transition regime and alignment with accounting

What it regulates

The law sets IRPJ, CSLL, PIS and Cofins under the legislation in force with its changes (art. 1) and rewrites provisions of Decree-Law 1.598 and of Laws 9.249 and 9.430. It defines the treatment of capital gains and losses (art. 31), impairment (art. 32) and share-based payment (art.

33), and provides that accounting method changes made after it do not alter federal taxes until a tax law regulates the point (art. 58). The early option applied to calendar year 2014 (art. 75) and general effect began on January 1, 2015 (art. 119).

Status
In force, with provisions repealed later. Article 30, on subsidies, was repealed by Law 14.789/2023 (art. 21, IV).
Point to watch in SAP
Control by sub-accounts and the differences between accounting and tax depend on the design of the chart of accounts and the assessment ledger.

ECD and ECF in SAP

In force

Law 9.249/1995, art. 13: prohibited deductions

What it regulates
To determine actual profit and the CSLL base, art. 13 prohibits, among other deductions, any provision (with exceptions such as vacation pay, the thirteenth salary and insurers' technical provisions), leases and rents not linked to production or sale, depreciation, maintenance and insurance of assets without that link, meals for partners and managers, non-compulsory contributions (with exceptions), donations (except those in § 2, with limits) and gifts. Paragraph 1 allows meals provided to all employees.
Status
In force in 2026. The compiled text refers to provisions of Law 9.430 in some cases.
Point to watch in SAP
Expense accounts that fall under a prohibition must generate an automatic, traceable addition in the assessment.

IRPJ and CSLL assessment in SAP

With a caveat

RIR/2018 (Decree 9.580), arts. 257 to 259: who must use actual profit

What it regulates
Article 257 lists the legal entities required to use actual profit: total revenue in the prior year above BRL 78,000,000.00 or proportional to the months, banks and other financial institutions, insurers, those with profits or gains from abroad, those that enjoy tax exemption or reduction, those that paid by estimate, factoring, securitization and other cases. Article 258 repeats the concept of actual profit and art. 259 defines net profit under commercial law.
Status
The Decree consolidates the legislation published up to 31 December 2016 (art. 3 of the decree). Later changes must be checked in the law and in the normative instruction.
Point to watch in SAP
The classification of each group company is kept in the company master, with the year the option was made.

IRPJ and CSLL assessment in SAP

With a caveat

IN RFB 1.700/2017: determination and payment of IRPJ and CSLL

What it regulates
The instruction covers the determination and payment of IRPJ and CSLL, and also PIS and Cofins as far as Law 12.973 is concerned. It deals with taxpayers, gross revenue, rates, estimates, the choice of payment method, actual profit, presumed profit, deemed profit, dividends, subsidies, loss offsets and initial adoption. It is the rule that turns the laws into procedure for the legal entity.
Status
The consolidated text lists amendments up to IN RFB 2.343 of 17/09/2026. IN 2.315/2026 repealed the items of art. 30, on CSLL rates.
Point to watch in SAP
Whoever implements the assessment should start from the consolidated text, never the original of 2017.

IRPJ and CSLL assessment in SAP

Rates, surtax and payment method4 rules

The 15% and the 10% surtax, the quarterly period, the monthly estimate and the deadlines.

In force

Law 9.249/1995, art. 3: 15% rate and 10% surtax

What it regulates
The IRPJ rate is 15%. The part of actual, presumed or deemed profit that exceeds BRL 20,000.00 multiplied by the number of months in the assessment period bears a 10% surtax. The surtax is paid in full, with no deductions (§ 4). The limit is proportional when the period is shorter than twelve months, and § 5 excludes local reinsurers under LC 126 from the surtax.
Status
In force in 2026.
Point to watch in SAP
The surtax limit depends on the number of months in the period, which matters in start-ups, mergers, spin-offs and wind-downs.

IRPJ and CSLL assessment in SAP

In force

Law 9.430/1996, arts. 1 and 5: quarterly assessment and payment

What it regulates
Article 1 requires IRPJ, under actual, presumed or deemed profit, to be determined by quarters ending on 31 March, 30 June, 30 September and 31 December. In mergers, spin-offs and wind-downs, assessment is made on the date of the event. The tax is paid in one payment by the last business day of the month after the quarter, or in up to three monthly installments, none below BRL 1,000.00, and tax below BRL 2,000.00 is paid in one payment (art. 5). Installments bear interest at the Selic rate.
Status
In force in 2026.
Point to watch in SAP
The payment calendar changes if the company chooses installments, and each installment needs its own document and due date.

IRPJ and CSLL assessment in SAP

In force

Law 9.430/1996, arts. 2, 3 and 6: monthly estimate and annual adjustment

What it regulates

A legal entity under actual profit may choose to pay the tax every month on an estimated base, applying to gross revenue the percentages in art. 15 of Law 9.249 (art. 2). The rate is 15% and the part of the monthly base above BRL 20,000.00 pays a 10% surtax. The option is irrevocable for the year and is made with the January payment (art.

3). Actual profit is determined on 31 December. The estimated tax is due on the last business day of the following month, and the positive December balance is due by the last business day of March, or January for the month of December (art. 6). A negative balance goes to refund or to the offset in art. 74.

Status
In force in 2026.
Point to watch in SAP
The estimate, the suspension balance sheet and the balance of the annual adjustment need a month-by-month trail for ECF bookkeeping.

IRPJ and CSLL assessment in SAP ECD and ECF in SAP

In force

RIR/2018, arts. 217 to 220 and 623 to 625: periods, estimate and surtax

What it regulates
The regulation repeats, in its own articles, quarterly assessment (art. 217), annual assessment (art. 218), payment by estimate (arts. 219 and 220), the 15% rate (art. 623), the 10% surtax on the part above BRL 20,000.00 per month (art. 624) and the non-reducibility of the surtax (art. 625). Each paragraph shows the source law in parentheses.
Status
Text of the regulation consolidated up to 2016. For the current wording of each point, check the source law indicated.
Point to watch in SAP
It helps locate, in one place, the article of law behind each rule implemented.

CSLL4 rules

The contribution that goes with IRPJ: base, rate and the link to the tax rules.

With a caveat

Law 7.689/1988, arts. 1 to 3: the contribution, the base and the rate

What it regulates
The law creates the social contribution on the net profit of legal entities, meant to fund social security (art. 1). The calculation base is the result for the year before the provision for income tax, adjusted by the additions and exclusions in art. 2. Article 3 sets the 9% rate for other legal entities (item III) and has specific rates for insurance, payment institutions and other financial institutions, in the wording given by LC 224/2025.
Status
In force, with differentiated rates and effective dates. The compiled text also shows wording given by Law 15.525/2026.
Point to watch in SAP
The rate must be set by type of legal entity and by date, not fixed in the program.

IRPJ and CSLL assessment in SAP

In force

Law 9.249/1995, art. 20: CSLL base under estimates and presumed profit

What it regulates
For those who pay CSLL by estimate or quarterly under presumed profit, the base is a percentage of gross revenue: 32% for the activities in art. 15, § 1, III (services in general, intermediation, leasing and others), 38.4% for the loan and discount operations of Simple Credit Companies and 12% for other gross revenue, after returns, cancelled sales and unconditional discounts.
Status
In force in 2026. The LC 224 increase for presumed profit is in the entry for the LC itself.
Point to watch in SAP
Revenue must be classified by activity at the source, because the CSLL base and the IRPJ base use different percentages.

IRPJ and CSLL assessment in SAP

In force

Law 9.430/1996, arts. 28 to 30: CSLL follows the tax rules

What it regulates
Article 28 applies to the assessment and payment of CSLL the rules of the legislation in force and those of arts. 1 to 3, 5 to 14, 17 to 24-B, 26, 55 and 71 of the law itself. Article 29 defines the base for those under presumed or deemed profit or exempt from bookkeeping: art. 20 of Law 9.249 plus capital gains, investment income and other revenue. Article 30 provides for the monthly estimated payment of those who chose the tax estimate.
Status
In force in 2026.
Point to watch in SAP
The payment method chosen for IRPJ also applies to CSLL, and the setup should link the two.

IRPJ and CSLL assessment in SAP

Replaced

IN RFB 1.700/2017, art. 30: CSLL rates by type of company

What it regulates
Article 30 listed the CSLL rates by type of legal entity, with periods of a higher rate between 2015 and 2018 for financial institutions and credit unions and 9% for the others. In the consolidated text, the mark of repeal by IN RFB 2.315 of 18/03/2026 appears on the items of the article.
Status
The rate in force must be read in Law 7.689, art. 3, with the wording of LC 224/2025. The exact list of what remains of art. 30 must be checked in the official text.
Point to watch in SAP
Old setup based on this article must be reviewed against the law.

Presumed profit and deemed profit4 rules

Who may opt, the percentages on revenue and the cases of deemed profit.

With a caveat

Law 9.249/1995, art. 15, and Law 9.430/1996, arts. 25 and 26: presumed profit

What it regulates

The tax base is a percentage of gross revenue: 8% in general, 1.6% on fuel resale, 16% on transport (except cargo) and certain financial institutions, and 32% on services in general, intermediation, leasing and other activities in item III, except hospital and diagnostic support services that meet the legal conditions (art.

15, § 1). With mixed activities, the percentage of each applies (§ 2). Presumed profit adds this amount to capital gains, financial income and other revenue (Law 9.430, art. 25). The option covers the whole year and is made with payment of the first installment (art. 26).

Status
In force. LC 224/2025 adds 10% to these percentages on the part of revenue above BRL 5,000,000.00 in the year (art. 4, § 5).
Point to watch in SAP
Splitting revenue by activity is the central point: without it, the percentage cannot be applied revenue by revenue.

IRPJ and CSLL assessment in SAP

With a caveat

RIR/2018, arts. 587 and 588, and IN RFB 1.700, art. 214: who may opt

What it regulates
A legal entity may opt for presumed profit if its gross revenue in the prior year was up to BRL 78,000,000.00, or BRL 6,500,000.00 per month of activity when the period was shorter than twelve months, and it is not required to use actual profit. The option is final for the year and is made with payment of the first or only installment. Assessment is quarterly. IN 1.700 repeats the rule in art. 214 and adds, in § 3-A, the treatment of those who start to have profits from abroad in the year.
Status
The amounts above come from the regulation and the instruction. Law 9.718/1998, art. 13, is the source of the limit.
Point to watch in SAP
The prior-year revenue limit requires the consolidated figure by CNPJ (Brazilian company tax ID), and the option must be recorded with the payment date.
In force

Law 8.981/1995, art. 47, and RIR/2018, arts. 602 to 604: deemed profit

What it regulates
Profit is deemed when, among other cases, a taxpayer required to use actual profit does not keep bookkeeping in line with commercial and tax laws, the bookkeeping shows signs of fraud or defects that make it unusable, the taxpayer does not present the books, opts improperly for presumed profit or does not keep the general ledger in good order. When revenue is known, the taxpayer may pay the tax on deemed profit (RIR, art. 604). The base is gross revenue with the percentages in art. 15 of Law 9.249 increased by 20% (Law 9.249, art. 16).
Status
In force. Item V of art. 47 appears as repealed in the compiled text.
Point to watch in SAP
The consistency of the general ledger and the journal is part of the proof: a bookkeeping failure can change the whole regime.
With a caveat

IN RFB 1.700/2017, titles XI and XII and art. 33: presumed and deemed profit

What it regulates
The instruction details presumed profit and the presumed result (title XI), with determination, the cash basis and ancillary obligations, and deemed profit (title XII), with known or unknown revenue. Article 33 deals with the percentages for hospital services and diagnostic support: § 4 lists cases where the benefit does not apply.
Status
IN RFB 2.343 of 17/09/2026 gave new wording to § 4, I, repealed items II and III and added items IV and V. How this applies to each company is for the client to read.
Point to watch in SAP
Records of health service providers need review against the current text of art. 33.

Interest on equity and dividends4 rules

The deduction of interest, the calculation base, the withholding and the treatment of dividends.

With a caveat

Law 9.249/1995, art. 9: interest on equity

What it regulates
A legal entity may deduct, in determining actual profit, interest paid or credited individually to the owner, partners or shareholders as remuneration of equity, calculated on equity accounts and limited to the pro rata daily change in the TJLP, according to the compiled text. Payment depends on profits at least twice the amount of the interest. The tax withheld is an advance for a beneficiary under actual profit and final taxation for the others. Paragraph 7 allows the interest to be counted toward the mandatory dividend.
Status
In force. The withholding rate was changed by LC 224 (separate entry). Paragraph 11 applies the rule to CSLL too.
Point to watch in SAP
Each JCP credit requires a calculation memo, the withholding, the beneficiary and a record that it was counted toward the dividend.

IRPJ and CSLL assessment in SAP

With a caveat

Law 9.249/1995, art. 9, §§ 8 to 12: accounts that make up the base for interest

What it regulates
Paragraph 8 lists the equity accounts used in the calculation: paid-in share capital, capital reserves, profit reserves (except the tax incentive reserve in art. 195-A of Law 6.404), treasury shares and accumulated profits or losses. Paragraphs 8-A to 8-C, added by Law 14.789/2023, exclude positive changes that arise from corporate acts between related parties without actual inflow of assets and apply from January 1, 2024. Paragraph 12 includes in share capital all kinds of shares, even if classified as liabilities.
Status
In force since 2024 under § 8-C.
Point to watch in SAP
The tax incentive reserve leaves the base: its ledger account must be identified.
With a caveat

Law 9.249/1995, art. 10, and IN RFB 1.700, art. 238: profits and dividends

What it regulates
Profits or dividends calculated on results from January 1996, paid by legal entities under actual, presumed or deemed profit, are not subject to withholding tax and do not enter the beneficiary's base in Brazil, subject to arts. 6-A and 16-A of Law 9.250, in the wording of the compiled text. IN 1.700 deals, in art. 238, with presumed and deemed profit: the base, less IRPJ, CSLL, PIS and Cofins, may be distributed and, with accounting books, the larger actual profit.
Status
The compiled text refers to Law 9.250. The part of the IN may lag behind the law, and the official text prevails.
Point to watch in SAP
Distribution above the presumed base requires full bookkeeping to support the actual profit.
With a caveat

LC 224/2025, art. 8: 17.5% withholding on interest

What it regulates
Article 8 of LC 224 gives new wording to § 2 of art. 9 of Law 9.249: the interest is subject to withholding tax at 17.5% on the date of payment or credit to the beneficiary. The law was published on 26 December 2025 and, as a rule, takes effect from January 1, 2026 (art. 14, III).
Status
In force in 2026, according to the compiled text of Law 9.249, which carries the LC 224 mark.
Point to watch in SAP
Withholding set up with the old rate must be reviewed for events from 2026 onward.

Tax losses and offsets3 rules

The 30% limit on loss offsets and the offset of credits against debts.

With a caveat

Law 8.981/1995, art. 42, and Law 9.065/1995, arts. 15 and 16: 30% limit

What it regulates
Net profit adjusted by additions and exclusions may be reduced by the offset of tax loss by 30% at most (Law 8.981, art. 42, and Law 9.065, art. 15). The same limit applies to the offset of the negative CSLL base (Law 9.065, art. 16). The offset is valid only for those who keep the books and documents that prove the loss or negative base. The part not offset may be used in later years.
Status
In force. Decree-Law 1.598, art. 64, mentions a period of four periods and has no effect because of the later percentage limit.
Point to watch in SAP
The balance of loss and negative base needs control by period, in part B of the assessment ledger.
With a caveat

IN RFB 1.700/2017, arts. 203 to 205: loss offsets

What it regulates
Article 203 repeats the 30% limit on adjusted net profit and requires the books that prove the loss. Article 204 allows, for companies inactive since 2009 and for companies in liquidation or bankruptcy, the offset of capital gains without the limit when the sale proceeds pay debts to the Federal Government. Article 205 only lets non-operating losses be offset against profits of the same nature.
Status
Consolidated text.
Point to watch in SAP
Non-operating losses need separate control, because they offset only against profit of the same nature.
With a caveat

Law 9.430/1996, art. 74: offset of credits against debts

What it regulates
A taxpayer with a credit eligible for refund or reimbursement of a tax administered by the Revenue Service may offset it against its own debts for any taxes it administers, by declaration. The declaration extinguishes the credit, but only definitively if it is approved. The approval period is five years (§ 5) and the declaration is an admission of debt (§ 6). Paragraph 3 lists credits and debts that cannot be offset, among them the monthly estimate debts of IRPJ and CSLL, as shown in the compiled text.
Status
In force, with several references to later acts. The reach of each restriction must be confirmed in the official text.
Point to watch in SAP
The choice between payment, refund and offset of a negative balance must leave a trail, with the declaration number.

IRPJ and CSLL assessment in SAP

Investment subsidies6 rules

From the old rule in art. 30 of Law 12.973 to the tax credit of Law 14.789.

Replaced

Law 12.973/2014, art. 30: investment subsidies

What it regulates
Article 30 allowed investment subsidies booked in a profit reserve to be excluded from actual profit. Article 21, IV, of Law 14.789/2023 repealed the article, effective January 1, 2024.
Status
Repealed. The old text still appears in IN RFB 1.700, art. 198, and in debts from earlier years.
Point to watch in SAP
Calculations for years up to 2023 may have used the old rule and should not be reused without reading the law.
With a caveat

LC 160/2017, arts. 9 and 10: ICMS benefits as subsidy

What it regulates
Article 9 adds §§ 4 and 5 to art. 30 of Law 12.973: tax or financial-tax incentives and benefits of ICMS (Brazil's state value-added tax) granted by States and the Federal District are treated as investment subsidies, and requirements beyond those in the article are prohibited, even in cases not yet finally judged. Article 10 extends this to benefits created in breach of the Federal Constitution (CF) by state legislation published until the law took effect, provided the registration and deposit were made.
Status
Article 30 of Law 12.973 was repealed by Law 14.789/2023, which now governs the subject.
Point to watch in SAP
Matching ICMS benefits with the required state rule and registration is a separate record.

State tax benefits and incentives in SAP ICMS legislation and benefits

With a caveat

Law 14.789/2023, arts. 1 to 5: tax credit and qualification

What it regulates
A company under actual profit that receives a subsidy from any level of government to set up or expand a business may determine the subsidy tax credit. The credit is a right to IRPJ that can be reimbursed or offset. Qualification with the Revenue Service is required, with a grant act before the set-up or expansion that sets conditions and counterparts. After 30 days from the request with no response, the legal entity is considered qualified.
Status
In force, effective from January 1, 2024 (art. 22).
Point to watch in SAP
The grant act, the date of the qualification request and the counterparts make up the file for each subsidy.

State tax benefits and incentives in SAP

With a caveat

Law 14.789/2023, arts. 6 to 12: assessment, use and prohibitions

What it regulates
The credit is the subsidy revenue multiplied by 25%, determined in the ECF for the period of recognition. Only revenue linked to the set-up or expansion and recognized after the qualification filing counts, related to depreciation, amortization or rental expenses of capital goods, and limited to the amount of the expenses and the subsidy. Subsidy revenue stays outside the monthly estimate and is taxed in the annual adjustment. The credit may be offset or reimbursed in cash, and the Revenue Service reimburses in the 24th month if there was no offset. It is not part of the base for IRPJ, CSLL, PIS and Cofins.
Status
In force. The wording of art. 11 was changed by LC 214/2025, art. 534.
Point to watch in SAP
The limit on revenue per expense, accumulated since the grant act, calls for control by subsidy.

ECD and ECF in SAP

Replaced

IN RFB 1.700/2017, art. 198: subsidies, reserve and ICMS

What it regulates
The article describes the old rule: investment subsidies, booked in the reserve of art. 195-A of Law 6.404, do not enter actual profit, and the reserve may only absorb losses or increase capital. Paragraph 7 prohibits exclusion when the funds can be freely moved. Paragraph 8, added by IN 1.881/2019, treats ICMS benefits as subsidies.
Status
The consolidated text does not cite Law 14.789, which has its own regulation.
Point to watch in SAP
Control of the reserve and of part B of the e-Lalur and e-Lacs remains relevant for old balances.
With a caveat

LC 214/2025, arts. 401, 526 and 534: tax treatment of benefits

What it regulates
Article 401 gives amounts paid as compensation for onerous benefits the same tax treatment as the state tax benefit, for IRPJ, CSLL, PIS and Cofins. Article 534 amends Law 14.789: art. 11 now says the tax credit is not part of the IRPJ and CSLL base, and art. 17 keeps federal IRPJ and CSLL incentives, including those of the Manaus Free Trade Zone, Sudene and Sudam. Article 526 changes Law 12.350, art. 30, on innovation subsidies.
Status
In force, with effects as stated in the articles.
Point to watch in SAP
Those with a state benefit in transition need to map what changes in federal treatment.

Consumption tax reform

Bookkeeping2 rules

The actual profit ledger, in digital form, and the control of differences.

In force

Decree-Law 1.598/1977, arts. 7 and 8: assessment ledger in digital form

What it regulates
The taxpayer must keep the actual profit assessment ledger, filed in digital form, with the net profit adjustments, the demonstration of actual profit, the tax assessment and the controls of losses to offset and of amounts that affect future periods. Article 7, § 6, requires filing in the public bookkeeping system. A taxpayer that fails to file the ledger or files it with inaccuracies pays a fine of 0.25% per month of net profit before IRPJ and CSLL, capped at 10% (art. 8-A).
Status
In force in 2026.
Point to watch in SAP
The ECF depends on well-mapped ledger accounts and on a control balance for each adjustment.

ECD and ECF in SAP SPED legislation

With a caveat

IN RFB 1.700/2017: e-Lalur, e-Lacs and part B

What it regulates
The instruction covers parts A and B of the e-Lalur and e-Lacs. The amount excluded in part A for a subsidy or prize on the issue of debentures is controlled in part B, to be added back when the conditions are breached (art. 198, § 5, and art. 199, § 6). The bookkeeping title deals with recording the adjustments and the annual assessment.
Status
Consolidated text. The ECF is governed by a separate instruction.
Point to watch in SAP
The balance in part B is the highest risk point in migration and in group consolidation.

ECD and ECF in SAP

Reduction of benefits and consumption reform4 rules

What LC 224, LC 214 and LC 227 change for IRPJ and CSLL.

With a caveat

LC 224/2025, art. 4: linear reduction of benefits, including IRPJ and CSLL

What it regulates
Federal incentives and benefits are reduced, among them those of IRPJ and CSLL. Paragraph 4 sets the rule by type of benefit, including, for presumed-base regimes, a 10% increase in the presumption percentages (item VII). Paragraph 5 limits the increase under presumed profit to the part of annual gross revenue above BRL 5,000,000.00, proportional by period and by activity. Paragraph 8 excludes the reduction in cases such as immunities, the Manaus Free Trade Zone and non-profit entities.
Status
The LC was published on 26/12/2025. Article 14 sets different effects on January 1, 2026 and on the first day of the fourth month after publication for taxes subject to the 90-day wait. The date for each tax is for the client to read.
Point to watch in SAP
Presumed profit percentages must be set with a revenue band and a date.

IRPJ and CSLL assessment in SAP

With a caveat

LC 224/2025, art. 7: CSLL rates of financial institutions

What it regulates
Article 7 gives new wording to art. 3 of Law 7.689: 15% for insurers and some institutions, 20% for the banks in item I of art. 1 of LC 105, 12% until 31/12/2027 and 15% from 01/01/2028 for payment institutions and others, and 17.5% until 31/12/2027 and 20% from 2028 for a third list. Other legal entities stay at 9%, under item III of the same article.
Status
Effective from the first day of the fourth month after publication (art. 14, I, b). The compiled text also shows wording from Law 15.525/2026.
Point to watch in SAP
The rate by type of institution requires a record that follows the date.
With a caveat

LC 214/2025: what changes for IRPJ and CSLL

What it regulates
The reform law creates IBS, CBS and the Selective Tax. On the points that touch IRPJ and CSLL, it amends other laws: exchange variations and future settlement operations, IRPJ and CSLL withholding on payments by public administration, Law 14.789 (art. 534) and Law 12.350 (art. 526). The text of the law has no rule of its own on including or excluding IBS and CBS in the IRPJ and CSLL base.
Status
In force, with phased effects. Reading the effects on each base is a point for the client's legal team.
Point to watch in SAP
Gross revenue now coexists with new taxes, and separating them in each document becomes an assessment requirement.

Consumption tax reform PIS and Cofins legislation

With a caveat

LC 227/2026: adjustments to LC 214 that touch IRPJ and CSLL

What it regulates
LC 227 amends LC 214. In the text of the law, the points involving IRPJ and CSLL are the split of the Simples Nacional, in art. 544 (annexes), and references to deductibility rules in income tax law for credit losses from January 1, 2027. The text creates no rule of its own for assessing IRPJ or CSLL.
Status
In force. Other points of LC 227 on LC 214 do not deal with IRPJ and CSLL.
Point to watch in SAP
Setup for the deductibility of losses must observe the date of January 1, 2027.
Who does what

Limit of our role: what stays with the client

DFSpro does

  • Designs and configures how SAP keeps the regime, revenue by activity, adjustments, control balances and withholdings.
  • Tests the result: document, ledger, assessment and payment slip matched period by period, with evidence.
  • Points to the source of each item and its reach.

Stays with the client

  • Deciding the regime, the use of each incentive, the interest calculation and the position on each adjustment.
  • Checking with the company's legal team and accountant what each rule and each court decision means.
  • Determining and deciding on fines, refunds or offsets.

The tax position is the client's decision.

To go deeper

Where each point is handled in SAP

Each topic below has an SAP service page, linked to the rules here.

IRPJ and CSLL assessment

Actual profit, presumed profit, estimates, adjustments and payment slips for each period.

IRPJ and CSLL assessment in SAPActual profit rules

ECD and ECF

Digital assessment ledger and control of part B.

ECD and ECF in SAPBookkeeping rules

Benefits and incentives

Subsidies, ICMS benefits and the subsidy tax credit.

State tax benefits and incentives in SAPSubsidy rules

PIS and Cofins

Contributions on revenue coexist with IRPJ and CSLL on the same revenue base.

PIS and Cofins legislation

ICMS and benefits

The source of the state benefits treated as subsidy.

ICMS legislation and benefits

Consumption reform

How IBS and CBS come in and how the income tax laws were changed.

Tax reform legislationReform and LC 224

In practice

How to turn the rule into a check in the system

Step 01

Confirm the source

Open the link in the entry and check the current text.

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Step 02

Turn it into a test

Turn the point to watch into a check: revenue by activity, adjustment with a reason, control balance and withholding by beneficiary.

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Step 03

Record the decision

The regime and the reading of the rule are the client's. Keep the source link, the date and the name of who made the decision.

Frequently asked questions

Questions buyers ask about the IRPJ and CSLL rules

01Which law defines actual profit?+

Decree-Law 1.598/1977, art. 6: the net profit of the year adjusted by additions, exclusions and offsets. The rate and the surtax are in Law 9.249, art. 3. Classifying your company is up to you.

02What are the IRPJ and CSLL rates?+

IRPJ has a 15% rate, with a 10% surtax on what exceeds BRL 20,000.00 per month of the period (Law 9.249, art. 3). CSLL is 9% for other legal entities, with specific rates for financial institutions and insurance (Law 7.689, art. 3).

03Who must use actual profit?+

RIR/2018, art. 257, lists the cases, such as revenue above BRL 78,000,000.00 in the prior year, financial institutions and those with profits from abroad. The client decides the classification, with the accountant.

04What is the limit for opting for presumed profit?+

Revenue up to BRL 78,000,000.00 in the prior year, or BRL 6,500,000.00 per month of activity when the period was shorter, and not being required to use actual profit (RIR, art. 587).

05What are the presumed profit percentages?+

8% in general, 1.6% on fuel resale, 16% on passenger transport and 32% on services in general, among others (Law 9.249, art. 15). LC 224 adds 10% on the part of revenue above BRL 5,000,000.00 in the year.

06What is the monthly estimate?+

It is the actual profit option of paying the tax every month on an estimated base, with an adjustment on 31 December (Law 9.430, arts. 2 and 3). The option covers the whole year.

07How does the 30% loss limit work?+

Tax loss and the negative CSLL base can reduce at most 30% of adjusted profit (Law 9.065, arts. 15 and 16). The balance not used carries to later years.

08What changed in interest on equity?+

The withholding became 17.5% under LC 224 and the base of equity accounts was detailed by Law 14.789, with effect from 2024 (Law 9.249, art. 9).

09What happened to the subsidy rule?+

Article 30 of Law 12.973 was repealed by Law 14.789, which created the tax credit for investment subsidies, with qualification and assessment in the ECF, from January 1, 2024.

10Are ICMS benefits still an investment subsidy?+

LC 160 treated them that way when it amended art. 30 of Law 12.973, later repealed by Law 14.789. Treatment today depends on Law 14.789 and a specific act. Read it with the client's legal team.

11Does the tax reform end IRPJ and CSLL?+

No. LC 214 creates IBS and CBS and amends other laws, including points of Law 14.789. The text of the law has no rule of its own on IBS and CBS in the IRPJ and CSLL base.

12Is IN 1.700 still valid?+

Yes, with amendments up to IN RFB 2.343 of 17/09/2026, in the consolidated text. Parts of it, such as art. 30, had items repealed. Always use the consolidated text.

13Does DFSpro decide the regime or the position?+

No. The regime, the position and the use of a benefit are the client's decisions. Our job is to design SAP and prove its result.

Next steps

When the rule needs to become proof in assessment and bookkeeping

If your question is how SAP keeps revenue by activity, the actual profit adjustments and the control balances, and how accounting, assessment and payment slip close together, the conversation with DFSpro can start at the point that weighs most. The tax decision stays with you.