Recently enacted, the Law 14.973/24, among other measures, provides for the temporary and gradual relief of payroll, reducing labor costs for companies in sectors deemed strategic.

The payroll relief consists of replacing the base of the employer’s social security contribution on the payroll (CPP), as provided in Article 22 of Law No. 8.212/1991, with a levy on gross revenue (Social Security Contribution on Gross Revenue - CPRB, established by Law 12.546/2011).

For the purposes of CPRB, gross revenue is generally considered to be the amount received from the sale of goods and services in operations on one’s own behalf or on behalf of others, as well as any other income earned by the legal entity, regardless of its designation or accounting classification.

The legal text provides for measures to compensate for the loss of revenue resulting from the temporary payroll relief. The compensation measures include, for example, the reopening of RERCT (Special Regime for Exchange and Tax Regularization); the adjustment of real estate costs and the declaration of fiscal incentives for the increase of PIS/Cofins-Importation; debt renegotiation through the program Desenrola Agências Reguladoras (the equationalization of business debts with regulatory agencies); as well as actions to combat fraud and abuses in public spending.

Among the main sectors benefiting from the relief are the industry (leather, footwear, clothing, textiles, animal protein, machinery, and equipment); services (information technology, call centers, communication); transportation (road freight transport, urban passenger road transport, and metro rail transport); and construction (civil construction and heavy construction).

The relief allows companies to replace the CPP (20% on employee salaries) with a CPRB with rates ranging from 1% to 4.5%, depending on the sector and the type of service provided.

From January 1, 2025, until December 31, 2027, companies that opt for the CPRB must sign an agreement committing to maintain an average number of employees equal to or greater than 75%, using the previous year’s average for comparison. In case of non-compliance, the company will not be able to benefit from the CPRB starting from the year following the breach.

The reinstatement of charges will be gradual and will occur until 2028.

In 2024, companies that qualify will be exempt from the social security contribution and will maintain the contribution on revenue between 1% and 4.5%.

The social security contribution rate in 2025 will be 5%, with a reduction in the revenue-based rate to 0.8% to 3.6%. In 2026, the social security contribution will increase to 10%, and the incidence on revenue will reduce to 0.6% to 2.7%. By 2027, the social security contribution will rise to 15%, while the revenue-based contribution will range from 0.4% to 1.5%.

The full reinstatement of payroll charges will occur in 2028, with the return of the 20% social security contribution and the end of the CPRB.

During the transition period (2025 to 2027), for the purposes of calculating the amount due, the CPP will not apply to the 13th salary.

It is essential, however, that the company conducts a thorough analysis before adhering to the Law, as depending on the business sector, gross revenue may be high while the need for labor may be low, meaning that the proposed trade-off may not be suitable for a company with these specific characteristics.

By: Luciana Klug
Labor Law | CPDMA Team