Brazil expands tax settlement program and imposes 10% dividend tax on high payouts

In 2025 the Federal Treasury's tax settlement program (PGFN) recovered a record R$ 29 billion in credits, including R$ 14.5 billion through transactions. The 2026 edition adds new editais and modalities, offering discounts of up to 65 % for individuals and micro‑enterprises and 50 % for other taxpayers, with repayment periods of up to 120 months. Available options include transactions of active‑debt credits, non‑registered debt, contested tax litigation and the voluntary “Litígio Zero” regularisation scheme.

A separate fiscal change took effect in January 2026: Law 15.270/25 requires a 10 % withholding tax on dividends or profit distributions exceeding R$ 50 000 per month for each individual recipient. The tax applies to the total amount paid, creating a step‑effect that reduces net cash flow for shareholders. Companies must retain the tax at source, and the rule is already under challenge before the Supreme Court, affecting businesses, family enterprises and professional societies across Brazil.