The proposal amends Law 7,689/1988 and establishes a gradual increase in the Social Contribution on Net Profit (CSLL). The rate applied to fintechs, payment institutions, over-the-counter market administrators, and stock and commodities exchanges will rise from 9% to 12% in 2026 and to 15% in 2028. Capitalization companies and credit, financing and investment institutions will see increases from 15% to 17.5% in 2026 and to 20% in 2028.

Higher taxes for betting operators

The bill also raises the Gross Gaming Revenue Contribution for fixed-odds betting companies (bets). The current 12% rate will increase to 15% in 2026 and 2027, reaching 18% in 2028. The revenue will be allocated to social security, with priority for health initiatives. Between 2026 and 2028, part of the funds may exceptionally be transferred to states, the Federal District and municipalities to offset losses from Income Tax exemptions granted to civil servants.

New regularization program

The bill creates the Low-Income Individual Tax Regularization Program (Pert-Low Income), aimed at renegotiating overdue tax and non-tax debts up to the date of the law's publication. Individuals earning up to R$ 7,350 per month — or R$ 88,200 annually — in the 2024 tax year may join.
Those making up to R$ 5,000 per month will receive full benefits, while higher-income brackets will receive proportional reductions. Minimum installments will be R$ 200. Joining the program implies debt confession and exclusion from other installment plans, except the restructuring allowed under Law 10,522/2002.

Fixing distortions and additional rules

The bill also corrects a distortion related to the remittance of profits and dividends abroad. If the combined amount of IRPJ, CSLL, and withholding tax exceeds the legal limit (34%), the foreign beneficiary may request a refund of the difference within five years, aligning the rule with the National Tax Code.

The new CSLL and betting taxation rates will take effect four months after publication. Rules for foreign tax credits will apply starting the following year, while other provisions take immediate effect.

The report also includes anti–money laundering measures covering fintechs and illegal betting operators, such as semiannual compliance reports, liability for illegal advertising, and integration with antifraud systems.
One notable addition is the creation of the Regulatory Compliance Index for Betting (ICRA), which will measure operators’ adherence to regulations and may serve as a criterion for benefits or restrictions.

Official estimates suggest the bill could generate nearly R$ 5 billion in fiscal impact in 2026, R$ 6.3 billion in 2027, and R$ 6.7 billion in 2028.

Tension and government disputes

During the session, Eduardo Braga said the Ministry of Finance and the Federal Revenue Service opposed parts of the previous draft. The senator criticized the government’s shift:
“I am outraged because I negotiated in good faith with Senator Renan Calheiros to secure approval for a project of major macroeconomic importance for Brazil.”

Government Leader in the Senate, Jaques Wagner (PT-BA), went against the position of the Finance Ministry and supported Braga’s original report, which was ultimately approved:
“Politics does not exist without risk. I ask Senator Eduardo Braga to withdraw today’s amendment and keep last week’s version. Then I’ll take responsibility.”