The Chamber of Deputies approved the urgency regime for PDL 314/2025, which seeks to suspend the effects of Decree No. 12,499/2025, responsible for the recent increase in IOF rates.
The bill will still be voted on by the Chamber itself and, if approved, will proceed to the Senate. In other words, the legislative process is ongoing, and nothing changes until the PDL is definitively approved by both houses.
Meanwhile, all the requirements of the decree remain valid, including the new incidence of IOF on transactions involving drawn risk, at a rate of 0.0082% per day.
This point has generated controversy. The risk drawn—a transaction involving the advance of receivables—does not technically qualify as a credit transaction, which raises questions about the constitutionality of the charge.
Furthermore, the Federal Revenue Service itself has already recognized, in several statements, that the assignment of credits without co-obligation does not constitute a taxable event for the IOF.
In this scenario, there is room to judicially discuss the IOF requirement on the risk drawn, especially in light of the principle of legality and the limits of the Union’s tax jurisdiction.
