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Cintia Meyer, a tax partner at Martinelli Advogados in Brazil, tells ITR that imposing the IOF exclusively on virtual asset transactions would create “distinct and unequal treatment”.

She suggests it wouldn’t be right for only this type of investment to be subject to the IOF while other financial investments and assets are not.

“In this case, what we see is a purely revenue-driven objective,” says Meyer.

“Over the past year, Brazil has experienced a very aggressive increase in tax collection, and recent data confirms this trend for both 2024 and 2025. Various transactions have come under scrutiny, not as part of a regulatory policy, but as a means of increasing revenue.”

It’s important to recall that the IOF is an extra fiscal tax, Meyer highlights. Its purpose is not merely to raise revenue, but to influence economic behaviour, she says.

“For example, increasing IOF on credit operations aims to discourage excessive borrowing. It is designed to direct market behaviour,” she notes.

Imposing the IOF on virtual assets would therefore signal an intention to reduce or discourage transactions involving these assets, she argues.

“The key question is: why? What is the economic justification? What is the impact on economic activity?”

Meyer adds: “There appears to be no legal, economic or statistical basis for such a measure. Virtual assets are now part of mainstream investment behaviour, just like other asset classes.

“They do not cause harm to the economy, nor do they generate negative externalities that would justify this type of intervention.”

She argues that, on the contrary, imposing IOF could harm transactions involving virtual assets and restrict a free market environment where investors should have the freedom to choose among different asset classes and diversify their investments.

Fonte: Internacional Tax Review | Publicado em 23/12/2025 | Clique aqui e veja a publicação original.