Brazil-Canada Investment Taxation Event at TozziniFreire
On October 15, from 9 a.m. to 12 p.m., the new headquarters of TozziniFreire Advogados, located on Faria Lima Avenue, hosted the in-person event "Brazil-Canada: Investment Taxation in a Post-Tariff Scenario”, held in partnership with the Brazil-Canada Chamber of Commerce (CCBC), the Foreign Trade Commission, and the Legal Affairs Commission. The event brought together experts to discuss the impacts of recent tariff changes and the opportunities for Brazilian and Canadian investors.
The program was divided into two panels. The first addressed the new geopolitical context and Canada’s post-tariff strategy to diversify its partners, offering insights into how tariff changes influence trade relations and the search for new markets. The second panel focused on investment taxation in Brazil, highlighting key challenges and solutions to ensure legal certainty and competitiveness in the current landscape.
The event featured renowned professionals and industry experts. The opening remarks were delivered by Hilton Nascimento, President of the Brazil-Canada Chamber of Commerce (CCBC), who provided an overview of the commercial relationship between the two countries.
The first panel, dedicated to the new geopolitical context and Canada’s post-tariff diversification strategy, was moderated by Oswaldo Dalla Torre, partner at TozziniFreire Advogados. Panelists included Rafael Cortez, political scientist and partner at Tendências Consultoria; Guillaume Légaré, Head of South America at the Toronto Stock Exchange & TSX Venture Exchange; and Luiz Gabriel Todt de Azevedo from the Inter-American Development Bank – IDB Invest, who joined remotely.
The second panel, focused on investment taxation in Brazil, was moderated by Leonardo Miranda, partner at TozziniFreire Advogados. Discussions featured Renata Emery and Ricardo Maito, partners at TozziniFreire, as well as Leila Fernandes, Tax Partner at PwC, and José Marcelo Machado, Senior Manager of Tax Structuring at PwC.
Among the key topics discussed was Bill No. 1,087/2025, which proposes significant changes in dividend taxation and the application of the Minimum Personal Income Tax (IRPFM) for high-income taxpayers. The bill includes, for example, a 10% withholding income tax (IRRF) on monthly dividends exceeding R$50,000 for individuals, along with specific rules for taxpayers earning more than R$600,000 annually. The transitional rule, which maintains the current regime for profits or dividends approved for distribution until December 31, 2025, was also addressed.
Another highlight was the impact of the Brazil-Canada Double Taxation Agreement, particularly regarding the limitation of the IRRF rate to 10% and the possibility of credit availability in Canada, considering that the Canadian income tax rate is lower than Brazil’s. The discussion also covered tax benefits, adjustments, and integration mechanisms between legal entities and individuals, along with practical examples and clarifications on the application of the new rules. The event concluded with final remarks by Marcelo Mendo, Co-Coordinator of the CCBC Mining Commission.
The event reinforced TozziniFreire Advogados’ commitment to promoting relevant discussions for the market and contributing to the development of strategies that foster international business.