Global Daily Tax News, Brazil To Require Annual Beneficial Ownership Reporting, (Nov 10, 2025)

Brazil's Federal Revenue has released new Normative Instruction 2,290/2025 providing for new beneficial ownership reporting obligations covering investment funds, companies, and trusts.

The Normative Instructions provides for the creation of a new Digital Beneficial Owner Form (e-BEF), for the electronic reporting of who owns, controls, or benefits from an entity, including for complex structures, such as funds whose shareholders are other funds.

The return will be pre-filled with data available to the Federal Revenue Service.

The information provided will be included in the National Registry of Legal Entities (CNPJ).

A new criminal offence will be created for persons falsifying declarations.

The return will be due from the following entities:

• civil and commercial companies, associations, cooperatives and foundations, including those that are suspended or inactive, domiciled in the country and registered with the CNPJ;

• financial institutions and investment fund managers; and

• entities or legal arrangements (trusts) domiciled abroad that hold rights, carry out activities, or perform legal acts or transactions in the country for which registration with the CNPJ (Brazilian National Registry of Legal Entities) is mandatory.

Investment funds domiciled abroad must also report the data of their ultimate beneficial owners, except for those with 100 or more investors, provided that none of them has significant influence in a national entity.

The following entities will be exempt from reporting requirements:

• public companies;

• mixed-economy companies;

• publicly traded companies and their subsidiaries;

• individual micro-entrepreneurs; and

• sole proprietorships.

The form will be required within 30 days of:

• registration with the CNPJ;

• a change of beneficial ownership;

• the entity no longer being an exempted entity.

An annual update is required by the last day of each calendar year, regardless of if there are any changes to an entity's beneficial ownership.