Brazil: Government changes Tax on Financial Operations (IOF) rules

In brief

As of 23 May 2025, Decree No. 12.466, of 22 May 2025, which amends Decree No. 6.306, of 14 December 2007, the Regulation of the Tax on Credit, Exchange and Insurance Transactions – IOF, came into force.

The changes provide for an increase in tax rates on various transactions, summarized in the table below. 
 


Contents

More details

  Before After Observation
General credit operations (e.g., loans, discounts, advances, overdrafts, etc.) Entity borrower: 0.0041%. Entity borrower: 0.0082% per day. When the borrower is a Micro or Small Business (Simples Nacional), in an amount equal to or less than BRL 30,000.00, the rate is reduced to 0.00274%
Additional IOF rate on credit operations. Entity and individual borrowers: 0.38%

Entity borrowers: 0.95%

Individual and MEI borrowers: 0.38%

 
Zero tax rate on credit transactions involving a cooperative borrower.  

Limit on the overall amount, in the immediately preceding calendar year, of credit operations, as creditor and borrower, set at BRL 100,000,000.00

Includes central cooperatives, cooperative federations, cooperative confederations and other cooperative associations.

Cooperatives that exceed the overall limit are subject to the IOF-Credit tax. 
Foreign exchange transactions (i) for payment resulting from the acquisition of goods and services abroad; (ii) for withdrawals abroad; as well as (iii) for the acquisition of foreign currency in traveler's checks and for loading an international prepaid card. 3,38% 3,50% Situation applicable to international credit and debit cards.
Foreign exchange operations for the entry of funds into the country, including through simultaneous operations, relating to foreign loans. 0%

3,50% - Minimum average term of up to 364 days.

0% - Minimum average term of 365 or more days.

 
Exchange transactions for the acquisition of foreign currency in kind (cash) 1,10% 3,50%  
Foreign exchange transactions for the transfer of funds abroad, to make them available to residents of the country, or their spouse, partner or relative, whether consanguineous or related. 1,10%

Non-investment purposes (e.g., Capital, property purchase, donation, etc.): 3.50%

For investment purposes: 1.10%

The Government backed down on the initial increase that would be also applicable for investment purposes.
Other exchange transactions carried out for the (i) entry or (ii) transfer of resources abroad, not exempt or subject to specific rates. 0.38%

Entry: 0.38%

Exit: 3.50%

General rule.
Contributions over BRL 50,000.00 (considering all plans) to cover the cost of life insurance plans with survivor coverage (e.g., VGBL.)   5% Levy on the entire amount and not just on what exceeds BRL 50,000;
As a rule, the collection must be made by the insurer or EAPC. If this is not possible due to the lack of information on contributions made to plans of other entities, the responsibility becomes the insured's.
Rule valid until December 2026.

 

In the following day, via the new Decree No. 12.467, the Federal Government backed down from increasing the rates on foreign exchange transactions, transfers to and from abroad, relating to investment funds in the international market, maintaining the zero rate previously in force.

The new rates are effective immediately, without the application of any rule of anteriority.

These new IOF rates run counter to the previously stated objective of aligning with OECD standards, as prior to these changes there was a scheduled gradual reduction of the IOF rates to 0% by 2029. Nonetheless, dividends and interest on net equity (JCP) distributed to foreign shareholders by Brazilian companies remain subject to a zero IOF rate.

* * * * *

LOGO_TrenchRossiWatanabe_Brazil

Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

Contact Information
Clarissa Machado
Partner
Trench Rossi Watanabe, Sao Paulo
Read my Bio
clarissa.machado@trenchrossi.com
Reinaldo Ravelli Neto
Partner
Trench Rossi Watanabe, Sao Paulo
Read my Bio
reinaldo.ravelli@trenchrossi.com

Copyright © 2025 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.