Brazil Corporate Income Tax

Por , 15 de janeiro de 2024.

Real Profit (RPM/APM) and Presumed Profit (PPM) Regimes in Brazil: A Detailed Guide with Example Calculations

Brazil’s corporate income tax system offers two primary regimes for calculating income tax:

1. The Real Profit Regime, also called Actual Profit Regime (RPM or APM) and

2. The Presumed Profit Regime (PPM). 

Both have unique features and implications for businesses operating in Brazil. In this post, we’ll overview each regime in detail, including example calculations, and conclude with a comparison to help businesses choose the most suitable option.

Real Profit Regime or Actual Profit Regime (Lucro Real)

The Real Profit Regime is based on the actual profit of the company. It’s mandatory for certain types of businesses and optional for others. Here’s what you need to know:

Tax Calculation: Tax is calculated on the company’s actual net income. For example, if a company has a gross income of BRL 5,000,000 and allowable deductions (operational expenses, depreciation, etc.) of BRL 2,000,000, the net income would be BRL 3,000,000.

Tax Rates and Payments: The corporate income tax rate under this regime is 15%, with an additional 10% on annual net income exceeding BRL 240,000. So, for our example with a net income of BRL 3,000,000, the tax would be BRL 450,000 (15% of BRL 3,000,000) plus BRL 276,000 (10% of BRL 2,760,000, which is the amount exceeding BRL 240,000), totaling BRL 726,000.

Presumed Profit Regime (Lucro Presumido)

The Presumed Profit Regime simplifies tax calculation by using a fixed percentage of gross revenue as the taxable base. It’s suitable for smaller businesses. Key aspects include:

Tax Calculation: The taxable income is presumed based on a fixed percentage of the gross revenue. For instance, if a service company has a gross revenue of BRL 1,000,000, and the presumed profit rate for services is 32% (Services Rate), the presumed profit is BRL 320,000.

Tax Rates: Applying the same corporate income tax rate of 15%, the tax on the presumed profit of BRL 320,000 would be BRL 48,000. There is no additional 10% tax as the presumed profit is below the BRL 240,000 threshold.

Comparison Between Real Profit and Presumed Profit Regimes

When choosing between the Real Profit and Presumed Profit Regimes, businesses should consider the following factors:

1. Tax Burden: In our examples, the Real Profit Regime results in a higher tax (BRL 726,000) compared to the Presumed Profit Regime (BRL 48,000). However, this can vary greatly depending on actual profits and deductions.

2. Complexity and Compliance Costs: The Real Profit Regime requires more detailed bookkeeping and compliance, leading to higher administrative costs. The Presumed Profit Regime is simpler and often cheaper to comply with.

3. Predictability: The Presumed Profit Regime offers more predictability in tax liabilities, as it’s based on gross revenue rather than actual profits.

Conclusion

Choosing the right tax regime in Brazil – Real Profit or Presumed Profit – depends on various factors, including the size of the business, the nature of its activities, its revenue, and its profit margins. While the Real Profit Regime offers more opportunities for tax optimization, it comes with greater complexity and compliance requirements. On the other hand, the Presumed Profit Regime offers simplicity and predictability, which can be advantageous for smaller businesses. Each company must assess its individual circumstances and, ideally, consult with Newco tax team to determine the most beneficial and compliant approach to taxation in Brazil.

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