Reforma tributária e justiça social no Brasil: análise crítica da Emenda Constitucional 132/2023 e da tributação dos super-ricos como instrumentos de redistribuição de renda (PL 1087/2025)

Abstract

This paper reframes Brazil’s tax overhaul around EC 132/2023 and Bill 1,087/2025. Using bibliographic and documentary methods, it examines the rollout of the dual VAT (IBS/CBS and a Selective Excise) under Complementary Law 214/2025 and the redesign of the Income Tax (with dividend withholding and annual offset, and corporate-personal integration). It argues that simplification of consumption taxes is necessary but insufficient to fix regressivity, requiring relief for essentials, targeted cashback, and calibrated selectivity. On income taxation, effectiveness hinges on full integration to prevent double taxation and arbitrage, together with an objective distinction between personal service providers and shareholders of service companies. The article recommends cooperative governance, distributional metrics by income decile, and transparency on effective tax rates. It concludes that coherence across bases, rates, and benefits—supported by continuous monitoring—is the condition for converting revenue efficiency into verifiable fiscal justice. It also situates these changes within Brazil’s broader multi-phase reform agenda