Imagine opening your refrigerator and discovering that now it charges a small fee to stay on, even if you barely use it. Aristotle recalled that “the wise man does not seek the maximum knowledge, but what is necessary to act”. It is precisely this practical knowledge that the investor will need to exercise to navigate the new tax logic introduced by Law No. 15,270/2025.
The rule establishes a minimum tax of 10% for those who earn more than 1.2 million reais per year. It doesn’t matter if part of the income was exempt: you will need to calculate the total paid and make up the difference, if applicable. This change, silent and profound, is changing the way large investors perceive their sources of income.
Take the example of the businessman who has built up a portfolio of dividend-paying stocks capable of generating R$50,000 per month. Add to that the R$50,000 per month he receives from his own company. Until last year, this R$100,000 per month was completely exempt. From now on, he will have to pay at least R$120,000 more per year.
The difference between the exempt dividend and the taxed fixed income also ends. For example, consider that the businessman above invests conservatively and obtains the equivalent of R$50,000 per month in income in fixed income funds taxed at 15%. Taking into account the compensation, he will also have to pay an additional amount, but this will only be R$30,000 for the year. In the end, he will have paid the same total tax as the previous investor.
In other words, for large commercial investors, the benefit of creating a dividend-exempt portfolio ends. But this is where strategy becomes important. If this businessman invests in the right products, he can be exempt from this IR.
The search for applications that do not list income on the IR report is expected to increase. It is not a question of investing in something that does not yield anything, but in something whose return is not recorded year after year. There are products always declared at their cost value, without any increase until reimbursement. If there is no declared income, nothing is added to the minimum tax base. So, the businessman above who earns up to R$50,000 in monthly dividends from his business could be exempt from this additional charge. I describe some of these products below.
Fixed income securities without intermediate interest payments work like this. The gain accumulates within the paper and only materializes at maturity. During the entire period, the report only shows the purchase value, which reduces the impact on the annual income considered by the tax administration. For those who need to control the volume of taxable income, this accounting detail makes the difference.
The same applies to funds without quotas, such as FIDCs, as well as to the VGBL and PGBL pension funds. In the case of the latter, in addition to being declared at cost price, they allow the portfolio to be reorganized internally without making any gains. In the case of Social Security, this benefit lasts for years and becomes a valuable element in the planning of those who need to balance their taxes.
The change also affects investors who previously rejected stock funds due to the 15% capital gains tax rate on the stock, which ended up affecting the dividend as well. With the minimum tax, the exemption of direct dividends loses its appeal and the funds become more competitive. They are declared at cost, the deferral of tax and compensation makes no difference between investing in the fund or directly. Additionally, they also have professional management, which can generate additional efficiency.
Ultimately, the new minimum tax does not lead investors to “no income” products, but to a new way of interpreting income. In an environment where all income above R$1.2 million must reach 10% tax paid, deferring taxation becomes as valuable as reducing it. Adjusting metrics, as Aristotle would recommend, becomes not only prudent, but essential to intelligently navigate this new tax scenario.
Michael Viriato is an investment advisor and founding partner of Investor House.
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