Currently under review in the Chamber of Deputies, Brazil, Bill No. 165/2025, introduced by Congresswoman Adriana Ventura (Novo-SP), proposes allowing the calculation of tax credits for the Social Contribution on Net Income (CSLL) on revenues from investment subsidies. The proposal aims to change the current system, which limits such benefits to tax credits calculated only on the Corporate Income Tax (IRPJ), at a rate of 25%, and extends it to CSLL, which has a rate of 9%.

The legislative initiative seeks to align the taxation of subsidies with the incentive purpose of the tax benefit, recognizing that these values do not constitute actual profit but rather a governmental encouragement for regional and sectoral development. The author of the bill also argues that by not allowing the calculation of the credit on CSLL, the current structure neutralizes part of the originally granted incentive, thus creating a distortion that harms companies investing in expansion and productive structuring. Another central point of the bill is the explicit prohibition of retroactive taxation on the reserve of tax incentives.

Finally, the proposal stipulates that, if approved, the new tax system can only take effect from the enactment of the future and anticipated law.

This new measure could directly impact companies benefiting from state or federal investment subsidies, particularly in the industrial and agro-industrial sectors, as it will allow for greater fiscal utilization and predictability in tax planning.

The bill is proceeding in summary form in the Chamber of Deputies and will be reviewed by the Finance and Taxation, Constitution and Justice, and Citizenship committees. If approved, it will move to the Federal Senate for further consideration.