(PT) Regime Especial de Atualização e Regularização Patrimonial

Law No. 15,265/2025, enacted last Friday (November 21, 2025), established the Special Regime for Asset Update and Regularization (REARP) and incorporated matters previously included in Provisional Measure No. 1,303/2025. It also introduced important changes to the PIS and Cofins tax compensation system and other fiscal provisions.

REARP: the regime allows taxpayers to update the value of assets with reduced taxation and to regularize lawful assets and rights that were undeclared or incorrectly declared up to December 31, 2024.

Tax compensations: the law classifies as “undeclared” compensation requests based on nonexistent payment documents or PIS/Cofins credits that have no connection to the taxpayer’s business activity.

Other changes: the law includes withholding income tax (IRRF) on remuneration from securities lending and new rules for calculating hedge results involving foreign counterparties.

Recommended actions: taxpayers should promptly review movable and immovable assets eligible for update or regularization and reassess their federal tax compensation strategies to mitigate risks and fiscal impacts.