Triplicação da Tributação de Direitos Autorais (MP 690/2015)
Definition
Medida Provisória 690/15 eliminated the reduced-base calculation for copyright/author entities. Previously, IRPJ and CSLL were calculated on a presumed profit of 32% of revenue (per Lei 9.430/96). The new rule requires taxation on 100% of gross receipts. The government justified this as alignment with salaried employees' tax treatment, but the effect was a 3x increase in effective tax burden for creator-owned companies.
Key Findings
- Financial Impact: R$ 16,000–R$ 24,000 per R$ 100,000 in annual royalty income (24% combined IRPJ+CSLL rate applied to additional R$ 68,000 of exposed base); or ~16–24% of gross revenue for copyright-dependent income streams.
- Frequency: Continuous/Permanent (applies to all copyright/royalty companies since Jan 1, 2016)
- Root Cause: Tax law change (MP 690/15) removed presumed profit deduction; lack of grandfathering or transition relief for established creator entities
Why This Matters
The Pitch: Brazilian artists and writers who created companies to receive copyright income lost 66% more revenue annually post-2016 due to tax base expansion. A freelance writer/artist earning R$ 100,000/year in direct royalties faces ~R$ 16,000–R$ 24,000 additional annual tax burden (depending on IRPJ+CSLL rates at ~24% combined).
Affected Stakeholders
Artistas (visual, performing), Escritores, Cineastas, Produtores de conteúdo, Gestores de direitos de imagem/marca/voz
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Financial Impact
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Methodology & Sources
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Related Business Risks
Aumento da Alíquota de IVA em Comercialização de Obras de Arte (Lei 214/2024)
Mecanismo de Dedução 70% sem Garantia de Destinação em Taxa de Streaming (PL Streaming)
Royalties Internacionais Perdidas (Streaming e Micro-Sync)
Direito de Sequência Não Coletado (Resale Royalty Non-Compliance)
Atraso de Pagamento de Royalties (Distribution Chain Friction)
Erro de Distribuição Entre Composição e Gravação (Publishing Split Calculation)
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