Income Tax Reform 2026: Taxation of Dividends in 2026, Minimum Personal Income Tax, and the Impacts of Bill 1,087/25 for Business Owners and Business Families
- Isabella Nogueira
- Feb 18
- 4 min read
The Senate approved Bill 1,087/25. Most analyses stopped at this point, as if it were just another tax update.
It is not.
This is not news.
It's an ultimatum.
From now on, any entrepreneur, high-income professional, investor, or business family that does not reorganize its income stream, profit distribution, and corporate structure by 2025 will be unknowingly signing an authorization to pay more tax than it should for the coming years.
And here's the first uncomfortable truth:
Bill 1.087/25 is not about taxing dividends starting in 2026; it's about control and who defines the narrative of wealth. It's about who will be exposed and who will remain protected.
If you understood this, you're already years ahead of the average person.
What really changes with Bill 1.087/25 (and why this matters to those with assets)?
Bill 1.087/25 alters three essential pillars of income in Brazil:
The logic of the Personal Income Tax (IRPF) for the middle and upper classes;
The taxation of dividends, abolished decades ago and now resurrected in a new form;
The creation of the Minimum Personal Income Tax (IRPFM), which institutionalizes the taxation of those who concentrate income in tax-exempt or low-tax sources.
But none of that, in isolation, is the central point.
What really matters is this:
From 2026 onwards, invisible income will cease to be invisible and outdated asset structures will no longer be neutral.
The end of the era of "frictionless" dividends: dividend taxation in 2026 and the real impact on holding companies and family businesses.
The taxation of dividends is not just a new tax. It's a forced repositioning.
When dividends become taxable, three things happen:
1. Structures set up solely to reduce taxes cease to be sustainable.
Holding companies created solely for tax savings become a cost, transforming what was once an advantage into a liability.
2. Accumulated profits become a ticking time bomb.
If you don't distribute now, you'll distribute later, and then it's more expensive. If you distribute incorrectly, you create exposure. If you don't plan, you pay tax twice (individual income tax and income tax).
3. Estate planning enters alert mode.
Succession has always been considered taxation, but now it is monitored taxation, and the choices made in 2025 will have a permanent effect on future generations.
The Minimum Income Tax Return (IRPFM) and the side effect that almost nobody noticed.
IRPFM is the most ingenious, and most silent, mechanism created in recent years.
It creates a minimum tax floor that reaches:
business families;
sophisticated heritage structures;
those who live on tax-exempt income;
Those who accumulate dividends or retained earnings.
The message is simple:
Family businesses that rely on profits and dividends automatically come under scrutiny.
It's not punishment.
It's the new rule of the game.
Those who fail to adjust their structure by January 2026 may face ongoing costs.
2025 is the last year to decide how much you want to pay for the next 10 years.
The only information that matters is this:
2025 is the last year in which you still have the freedom to decide how you will be taxed.
From 2026 onwards, the choice will be up to the system, not you.
And here is the most relevant technical point:
Its current structure was designed for a Brazil that no longer exists.
Brazilian estate planning was designed for a country of:
Tax-exempt dividends;
neutral profits;
fractional income;
instrumental holdings;
Succession with low tax friction.
This country ended when the Senate approved Bill 1.087/25.
Now, only one distinction remains:
Those who adapt and those who become statistics.
The legal and economic risk of inaction.
The biggest risk of a tax system in transition is not the tax itself, but the grey area.
This is when companies, families, and professionals become paralyzed, believing that "it's better to wait."
Inertia is more expensive than taxation.
Why:
Those who wait miss the distribution timing;
Those who don't restructure end up paying on the wrong basis;
Those who fail to review contracts create inheritance disputes;
Those who fail to adjust their holdings fall into the IRPFM (Income Tax and Financial Transactions) trap without realizing it;
Those who postpone things until 2026 will end up paying to remedy what they could have planned for.
The question that separates those who protect assets from those who surrender assets.
There is only one strategic question now:
How much are you willing to pay for not reorganizing your structure by 2025?
She is a lawyer.
It's economical.
It is a succession.
It's emotional.
Depending on the answer, you can:
pay 15% more in dividends;
to lose corporate efficiency;
expose successors to IRPFM;
compromise family policies;
wasting unique opportunities.
The uncomfortable truth that transforms information into strategy.
If you have:
enterprise;
holding;
structured assets;
retained earnings;
income earned abroad;
or any succession strategy,
So Bill 1.087/25 isn't asking for your attention, it's demanding a decision.
Inaction is the most expensive choice of all.
How can I help you?
I work advising entrepreneurs, executives, and business families precisely on this critical point:
How much to distribute in 2025;
How to reorganize holding companies for tax efficiency;
Which contracts to review;
How to secure a succession plan;
How to reduce the impact of IRPFM;
How to align wealth, succession, and governance under the new rules.
If you want to understand the real impact of Bill 1.087/25 on your financial life, your holding company, and your succession, request a Strategic Meeting through my website.
2025 is the last year of fiscal freedom.
2026 is the year the bill comes due.
The difference between these two scenarios begins with a single conversation, and it starts here.
