by Edmo Colnaghi Neves (PhD), Murray Advogados, Brazil

A bill of complementary law is currently pending before the National Congress to levy a tax on what is referred to as large fortunes. Under the bill, a large fortune would be defined as personal net worth exceeding BRL 10,000,000.00, subject to tax at rates ranging from 1% to 3%, depending on the assets held as of January 1, with payment due by April 30 of each year.

The bill provides for certain deductions to arrive at this amount, such as the taxpayer’s debts and encumbrances, meaning that the taxpayer’s net worth will be considered. There are specific rules for valuing shares or equity interests in legal entities, as well as for jewelry, precious metals, works of art, and other movable assets, while other assets are to be valued at their market value.

The amount of the tax due may be reduced by the amounts paid as ITR (rural property tax), IPVA (motor vehicle ownership tax), and IPTU (urban property tax).

The Federal Constitution of 1988 grants legislative authority to the Federal Union to create this tax. The bill is still at an early stage and must be debated and approved by both legislative houses (the Chamber of Deputies and the Federal Senate), in addition to requiring presidential assent. As of now, the IGF (Tax on Large Fortunes) does not exist, but if approved this year, it could take effect in the following year.

There are arguments that the recent taxation of high incomes already constitutes a form of taxation on large fortunes, as well as that a 3% rate, over the course of several decades, could amount to confiscation, and therefore be subject to judicial challenge.

February 2026