Starting January 1, 2025, the rules governing payroll tax exemptions in Brazil have changed significantly for companies under the desoneração da folha de pagamento regime. Law No. 14.973/2024 establishes a transition regime that modifies how employer contributions to the social security system are calculated, shifting from a structure based solely on payroll to one that combines payroll with the company’s gross revenue.
New Contributions Structure
Traditionally, companies included in the desoneração regime could replace the Payroll Employer Contribution (CPP)—typically 20% of total salaries—with the Gross Revenue Contribution (CPRB), at reduced rates ranging from 1% to 4.5% depending on the sector. Law No. 14.973/2024 maintains this benefit until the end of 2024 but introduces a gradual reoneração schedule for 2025, 2026, and 2027. During this period, companies must pay both a portion of the payroll contribution and another based on gross revenue, progressively adjusting toward a full return to the traditional scheme.
The transition scheme is organized as follows:
| Year | Payroll Contribution (CPP) | Gross Revenue Contribution (CPRB) |
| 2025 | 5% |
0.8% to 3.6% (80% of the legal rate by sector)
|
| 2026 | 10% |
0.6% to 2.7% (60% of the legal rate by sector)
|
| 2027 | 15% |
0.4% to 1.8% (40% of the legal rate by sector)
|
| 2028 | 20% |
Not applicable (full return to traditional scheme)
|
Note: CPRB rates vary by sector (CNAE), with caps such as 4.5% in construction; the 2027 range has been corrected from 1.5% to 1.8% for accuracy. This hybrid approach requires greater precision in accounting and tax calculations, as applicable rates depend on each company’s sector, revenue volume, and total payroll.
Commitments for the Regime
In addition to dual-contribution calculations, the law introduces further conditions for retaining the benefit. Companies subject to CPRB benefits must maintain an annual average of employees equivalent to at least 75% of the workforce registered the previous year. Non-compliance may result in the loss of the desoneração regime not only for the current year but also for the following year.
Importance of Tax Planning
The shift to a hybrid social contributions model brings new operational and tax complexity for companies operating in Brazil. Finance and payroll teams must adapt by reviewing contribution calculation systems and updating internal processes to reflect variable rates; strengthening cash flow projections to account for the progressive reoneração impact; evaluating compliance scenarios and legal tax optimization opportunities; and ensuring fulfillment of labor and workforce requirements, which are essential for maintaining preferential regime access. Without proper tax and operational planning, companies could face unforeseen extra costs, penalties, or loss of benefits that, until 2024, significantly eased labor expenses.