The gap between the economic value of assets and the value reported in Brazilian income tax returns is a recurring reality. Real estate acquired many years ago, vehicles held for long periods, and assets incorporated into personal or corporate wealth over time often remain recorded at historical cost, even after significant appreciation.
Although permitted under the traditional tax framework, this situation generates relevant long-term effects: patrimonial distortions, increased tax costs in future disposal events, difficulties in corporate reorganizations, and additional risks in succession planning.
It was within this context that Law No. 15,265/2025 introduced the REARP — Special Regime for Asset Value Update and Regularization.
The logic behind REARP
REARP establishes a specific legal window allowing individuals and legal entities to update the value of certain assets to their market value, subject to the payment of tax at reduced rates, calculated on the difference between the previously declared value and the updated value.
The applicable rates are:
– 4% for individuals
– 8% for legal entities
This is an exceptional regime, designed to enable transparent and legally compliant asset reorganization, reducing distortions accumulated over time.
Eligible assets and temporal limitation
The regime allows for the update of:
– Real estate
– Vehicles
– Assets declared at values below market value
– Assets not properly reported in prior tax years
However, there is an objective temporal limitation: only assets acquired up to December 31, 2024 may be included in REARP. This cutoff reinforces the exceptional and temporary nature of the measure.
Deadlines and relevant restrictions
Adherence to REARP must occur within a restricted 90-day period, requiring prior planning, proper documentation, and technical analysis.
In addition, the law imposes restrictions on the disposal of updated assets, directly affecting patrimonial and business strategies:
– Real estate: prohibition on sale for a period of 5 years
– Vehicles: prohibition on sale for a period of 2 years
These limitations are not merely formal. They affect liquidity decisions, corporate reorganizations, succession planning, and structured transactions.
Impacts on asset and succession planning
From an asset planning perspective, REARP may represent a relevant tool to:
– Reduce distortions between economic value and tax value
– Increase future tax predictability
– Facilitate succession processes
– Organize family and corporate asset structures
On the other hand, asset value updates alter future tax bases, influence strategies involving donations, inheritance, and corporate reorganizations, and may generate significant medium- and long-term effects.
For this reason, the analysis of REARP should not be limited to a comparison of tax rates, but should consider its integrated legal, tax, and patrimonial effects.
Companies, governance, and strategic perspective
In the corporate environment, adherence to REARP is closely linked to governance practices, tax compliance, and asset transparency. Companies with significant real estate holdings or complex corporate structures must evaluate, in a coordinated manner:
– Accounting impacts
– Effects on future transactions
– Compatibility with growth, reorganization, or succession strategies
– Alignment with internal governance policies
In this context, asset value updates are a structural decision, not merely a tax-driven one.
Final considerations
REARP, established by Law No. 15,265/2025, represents a relevant legal opportunity for asset reorganization and regularization. However, it is an exceptional regime, with deadlines, limitations, and effects that extend over time.
Updating assets is not simply a matter of adjusting reported values. It is a decision involving strategy, governance, and legal certainty.
Well-organized assets are assets prepared for the future.
