Articles | Postado no dia: 10 September, 2026
Brazil’s Federal Revenue clarifies social security withholding rate for companies under the CPRB during transition period
Brazil’s Federal Revenue Service (RFB) has clarified the social security withholding rate applicable to companies that opted for the Contribution on Gross Revenue (CPRB) and provide services through labor outsourcing or contracted projects.
On August 20, 2026, the RFB’s General Coordination of Taxation published Cosit Consultation Ruling No. 153/2026, addressing an important issue for companies subject to the CPRB.
The question arose following Law No. 14,973/2024, which established the gradual return of payroll taxation between 2025 and 2027. Companies and service recipients had questioned whether the withholding rate applicable to their invoices would remain at 3.5% or increase to the general 11% rate.
According to the Federal Revenue Service, the social security withholding rate will remain at 3.5% throughout the transition period, from 2025 through 2027, for companies subject to the CPRB. The rate applies to the gross amount of the relevant invoice or bill.
Starting January 1, 2028, when companies return to the standard payroll contribution system, the withholding rate will increase to the general 11% rate.
Companies that do not opt for the CPRB remain subject to the 11% withholding rate.
The Federal Revenue Service based its interpretation on the fact that Paragraph 6 of Article 7 of Law No. 12,546/2011, which established the reduced withholding rate, was not repealed by Law No. 14,973/2024. In addition, Normative Instruction RFB No. 2,053/2021 was updated while maintaining the differentiated withholding system.
The ruling provides greater legal certainty for companies in the construction and infrastructure sectors, among other industries covered by the CPRB, which had faced disagreements with service recipients over the correct social security withholding rate.
Author: Iran Silva
