[World Tax News] Brazil Releases Guidance on 10% Increase in Presumed Profit Rates and More

Editorial Team – [2026] 185 taxmann.com 360 (Article)

World Tax News provides a weekly snippet of tax news from around the globe. Here is a glimpse of the tax happening in the world this week:

1. Brazil Releases Guidance on 10% Increase in Presumed Profit Rates

Brazil has issued Normative Instruction No. 2.306 dated 22 January 2026, providing guidance on the application of the 10% increase in presumed profit rates for companies with gross revenue exceeding BRL 5 million, as introduced by Complementary Law No. 224 of 26 December 2025.

Under the Presumed Profit (Lucro Presumido) regime, a simplified method for computing the tax base for Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL) tax liability is determined by applying prescribed profit margins based on industry, rather than actual profits.

The Instruction clarifies that the 10% increase applies only to the portion of gross revenue exceeding BRL 5 million in a calendar year. This threshold is apportioned across quarterly periods, effectively applying the increase to quarterly revenues exceeding BRL 1,250,000.

In the final quarter, total annual gross revenue must be reassessed, and corresponding adjustments to IRPJ and CSLL are made in accordance with the prescribed procedures. These adjustments account for the application of the increased rate in earlier quarters and whether the annual threshold is ultimately exceeded.

Where excess IRPJ and CSLL have been paid in prior quarters and cannot be fully offset against the final quarter liability, the taxpayer may claim a refund of the surplus.

Source – Complementary Law No. 224

2. Belgium Approves New Capital Gains Tax on Financial Assets

On 2 April 2026, the Belgian Chamber of Deputies approved legislation introducing a new capital gains tax on financial assets. The scope covers financial instruments such as shares and bonds, as well as crypto-assets, savings-oriented insurance contracts, currencies, and investment gold.

The tax applies to individuals, certain non-profit entities, and private foundations that are tax resident in Belgium. It is levied at varying rates based on the category of gain:

• Category A – 33% on internal capital gains, including transfers of shares to companies controlled by the transferor and/or their family;
• Category B – Progressive rates ranging from 1.25% to 10% on gains from substantial shareholdings (at least 20%), with an exemption for gains up to EUR 1 million over a five-year period. Where shares are sold to a non-EEA entity, a flat rate of 16.5% applies, along with the EUR 1 million exemption;
• Category C – 10% on gains from other financial assets, subject to an annual exemption of EUR 10,000, indexed up to EUR 15,000 for taxpayers with no capital gains in the preceding five years.

The law also provides that the tax applies only to gains accruing from 1 January 2026, with specific rules to determine the valuation of assets held as of 31 December 2025.

The legislation will enter into force upon publication in the Official Gazette and will apply retroactively from 1 January 2026. Withholding obligations for intermediaries will be effective from 1 June 2026, although taxpayers may opt out of withholding and instead self-assess their taxable gains.

Source – Sessional Paper 56K1244

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