Lucro Presumido, Lucro Real or Simples: Brazil’s corporate tax regimes explained
Guilherme Chambarelli
Published on
3 min read
In this article
Brazil has three main corporate tax regimes. Simples Nacional is a unified regime for small companies, generally unavailable to foreign-owned businesses. Lucro Presumido taxes a deemed profit based on a percentage of revenue and is available to companies with annual revenue up to BRL 78 million. Lucro Real taxes actual accounting profit, with adjustments, and is mandatory for larger companies and certain activities. The right choice depends on margins, cost structure and the client base.
Key points
- Simples Nacional is limited to small companies and, as a rule, closed to companies with foreign partners.
- Lucro Presumido uses fixed deemed-profit percentages; since 2026, they are 10% higher on revenue above BRL 5 million a year.
- Lucro Real is mandatory above BRL 78 million in revenue and for some activities.
- From 2027, CBS replaces PIS and Cofins under all regimes.
- The choice is made at the start of each calendar year and should be simulated.
Simples Nacional: who can use it?
Simples Nacional (Complementary Law 123/2006) combines several taxes in a single monthly payment, with rates that vary by revenue bracket and activity. It is available to micro and small companies with annual revenue up to BRL 4.8 million. Companies that have a legal entity as partner, a partner domiciled abroad or that are branches of foreign companies cannot use it. In practice, most subsidiaries of foreign groups are excluded.
Lucro Presumido: how does it work?
Under Lucro Presumido, corporate income tax (IRPJ) and the social contribution on net profit (CSLL) are calculated quarterly on a deemed profit equal to a percentage of gross revenue, regardless of actual margins. The traditional percentages are 8% for sales of goods and 32% for most services for IRPJ, and 12% and 32% for CSLL. IRPJ is charged at 15%, with a 10% surtax on deemed profit above BRL 60,000 per quarter, and CSLL at 9%.
Complementary Law 224/2025 increased the deemed-profit percentages by 10% (for example, 32% becomes 35.2%) on the portion of annual revenue that exceeds BRL 5 million, from January 2026 for IRPJ and from April 2026 for CSLL. The change is being challenged in court by some taxpayers.
Lucro Real: when is it mandatory?
Lucro Real taxes the actual profit, adjusted by additions and exclusions required by tax law. It is mandatory, among other cases, for companies with annual revenue above BRL 78 million, financial institutions, companies with foreign-source profits or capital gains and companies benefiting from certain tax incentives. Tax losses can be carried forward indefinitely, but offset is limited to 30% of the taxable profit in each period.
Side-by-side comparison
| Feature | Simples Nacional | Lucro Presumido | Lucro Real |
|---|---|---|---|
| Revenue limit | Up to BRL 4.8 million | Up to BRL 78 million | No limit |
| Tax base | Revenue, by bracket | Deemed profit | Actual adjusted profit |
| Foreign partners | Generally not allowed | Allowed | Allowed |
| Best for | Small local businesses | High real margins, simpler operations | Low margins, losses, large operations |
| PIS/Cofins until 2026 | Inside the unified payment | Cumulative, no credits | Non-cumulative, with credits |
What changes with the 2027 tax reform?
The reform affects consumption taxes, not corporate income tax. From 2027, CBS replaces PIS and Cofins for every regime, with broad credits regardless of whether the company is under Lucro Presumido or Lucro Real. This removes one of the historical differences between the two regimes and makes the income tax comparison even more important. Simples Nacional companies may choose to collect CBS and IBS under the regular rules.
How to choose
- Estimate actual profit margin and compare it with the deemed percentages.
- Check whether the activity or revenue makes Lucro Real mandatory.
- Consider expected losses in the first years, which only Lucro Real can use.
- Include the effect of dividend withholding introduced in 2026 for payments to individuals and non-residents.
- Review the decision every year.
Frequently asked questions
Can the regime be changed during the year?
As a rule, no. The option is made with the first tax payment of the calendar year and applies for the whole year.
Is Lucro Real always more expensive to manage?
It requires more detailed accounting and filings, but for low-margin businesses the tax savings often outweigh the extra cost.
Do dividends remain tax-exempt?
Not entirely. Since 2026, Law 15,270/2025 imposes 10% withholding on dividends paid abroad and on monthly dividends above BRL 50,000 paid to the same individual.
How Chambarelli Advogados can help
Our Corporate Taxation team and our Foreign Desk simulate the regimes with real numbers and support the choice each year. Book a meeting with one of our partners.
Informational content, updated October 2026. It does not replace advice on your specific case.
