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Provisional Measure No. 1,303/2025: IOF Adjustment and Other Significant Tax Measures

18/06/2025

On June 11, 2025, the Federal Government enacted Decree No. 12,499/25 and Provisional Measure No. 1,303/2025, introducing a broad set of changes to the taxation of financial transactions, tax offset mechanisms, and public expenditure rules. These measures aim to recover revenue following the partial rollback of previously announced policies, while also responding to sectoral demands and Congressional negotiations.

  1. IOF Adjustment: Reductions and Structural Changes
  • Corporate Credit: The fixed IOF rate was reduced from 0.95% to 0.38%.
  • Supply Chain Financing (Risco Sacado): The fixed rate was eliminated. Only the daily rate of 0.0082% applies, effectively reducing the tax burden on such operations by approximately 80%.
  • Receivables Investment Funds (FDICs): A fixed IOF rate of 0.38% is introduced on the primary acquisition of fund units, aligning the taxation of similar financial structures.
  • VGBL (Individual Life Insurance with Redeemable Savings Element):
    • Until December 31, 2025: IOF applies only to contributions exceeding R$ 300,000 per insurer.
    • As of 2026: A unified threshold of R$ 600,000 will apply, aggregating contributions made across different institutions.
    • Employer contributions to VGBL plans become exempt from IOF.
  • Foreign Exchange IOF: The exemption is extended to the repatriation of foreign direct investments, aligning it with the treatment already granted to transactions in the financial and capital markets.
  1. Sports Betting: Tax Increase
  • The tax rate on the gross revenue of betting platforms increases from 12% to 18%.
  • Revenue will be allocated to Social Security, with a specific focus on funding public healthcare services.
  • Enforcement actions will be intensified against unauthorized operators conducting betting activities in Brazil.
  1. Adjustments to Public Expenditure
  • “Pé-de-Meia” Education Incentive Program: Incorporated into the constitutional minimum spending on education, with an expected fiscal impact of R$ 12 billion.
  • Atestmed (INSS medical certificate system): Regulatory provisions revised.
  • Fishermen’s Insurance (Seguro Defeso): New eligibility criteria and budget allocation rules established.
  • Pension Compensation between Social Security Regimes: Now subject to budgetary availability.

Final Considerations

Businesses and investors should carefully assess the financial and operational impacts of the new rules and consider preventive tax planning as a strategic adaptation tool. While some sectors—such as supply chain financing—have benefited from tax relief, others, particularly investors and issuers of previously exempt securities, will face a higher tax burden.

For further information or a personalized impact assessment, our team is available for consultation.

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