On October 15, 2025, from 9 a.m. to 12 p.m., the new headquarters of TozziniFreire Advogados, located on Faria Lima, hosted the in-person event “Brazil-Canada: Investment Taxation in a Post-Tariff Scenario,” organized in partnership with the Brazil-Canada Chamber of Commerce (CCBC), the Foreign Trade Commission, and the Legal Affairs Commission. The meeting brought together specialists 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 strategy for diversifying partners after the tariff changes, offering reflections on how these changes influence trade relations and the search for new markets. The second panel focused on investment taxation in Brazil, highlighting the main challenges and solutions to ensure legal certainty and competitiveness in the current scenario.
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 discussed the overall context of commercial relations between the two countries.
The first panel, dedicated to the new geopolitical context and Canada’s diversification strategy post-tariff, was moderated by Oswaldo Dalla Torre, partner at TozziniFreire Advogados. Panelists included Rafael Cortez, political scientist and partner at Tendências Consultoria; Guillaume Légaré, Head for South America at Toronto Stock Exchange & TSX Venture Exchange; and Luiz Gabriel Todt de Azevedo from the Inter-American Development Bank – BID Invest, who participated remotely.
The second panel, on investment taxation in Brazil, was moderated by Leonardo Miranda, partner at TozziniFreire Advogados. The discussions featured Renata Emery and Ricardo Maito, partners at TozziniFreire, as well as Leila Fernandes, tax partner at PwC, and José Marcelo Machado, tax structuring senior manager at PwC.
Among the central topics, the analysis of Bill No. 1,087/2025 stood out, proposing significant changes in dividend taxation and the application of the Minimum Personal Income Tax (IRPFM) for high-income taxpayers. The bill, for example, provides for a 10% withholding income tax (IRRF) on dividends above R$ 50,000 per month for individuals, as well as specific rules for taxpayers earning more than R$ 600,000 per year. The transition rule, which maintains the current regime for profits or dividends whose distribution is approved until December 31, 2025, was also discussed.
Another highlight was the impact of the Brazil-Canada Double Taxation Agreement, especially regarding the limitation of the IRRF rate to 10% and the possibility of credit available in Canada, considering that the Canadian income tax rate is lower than Brazil’s. Other topics included 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 closing remarks were delivered 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 drive international business.
