The Law 15.525/26 has been signed, which reduces the tax burden on Brazilian reinsurers and relaxes rules for offsetting tax losses for these companies. The measure aims to correct tax asymmetries between national and foreign reinsurers.
Reinsurance acts, in practice, as the "insurance for insurers," assuming part or all of the risks to ensure the stability of the financial system in the event of large losses.
The proposal reduces the rate of the Social Contribution on Net Profit (CSLL) charged to local reinsurers from 15% to 9%. As a result, the taxation of these companies will be equal to the general rule applied to most non-financial companies in the country.
The law originated from PL 3540/26, from the Chamber of Deputies, which was approved in Plenary by the deputies in August and by the Senate in early September. The author of the proposal was Deputy Isnaldo Bulhões Jr. (MDB-AL). The rapporteur was Deputy Fernando Monteiro (PSD-PE), who modified the initial text.
Tax Losses
The law also relaxes the rules for offsetting financial losses from the tax base. Under the general rule, the offsetting of tax losses and negative CSLL calculation bases is limited to 30% of the company's profit in the period.
With the new legislation, local reinsurers are exempt from this 30% limit for offsetting losses that have not been deducted within three years from their assessment. This exemption also applies to losses recorded before the law's publication.
The text also exempts the collection of the additional Corporate Income Tax (IRPJ) on the profits of these companies.
Effective Date
The budget changes will occur gradually:
- starting January 1, 2027: the new CSLL rate (9%) and the new rules for offsetting tax losses will come into effect;
- starting January 1, 2030: the exemption from the additional IRPJ will come into effect.
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