Credit: Magnific
XP’s decision to temporarily suspend new investments in six fixed-income ETFs brought renewed attention to the method used to calculate income tax on funds investing in private securities linked to Brazil’s CDI interbank rate.
The suspension covered AMAB11, DEBB11, GICP11, LFIN11, MARG11 and NLFA11. According to the platform, the measure was adopted because questions remain about whether the applicable tax rate on gains should be 15% or 25%.
The scope of the decision is specific. XP suspended new purchases and transfers through its own channels but did not halt trading of the ETFs on B3. Clients who already held shares retained their positions, with no change to the amount invested or to the operation of the funds. XP described the measure as temporary and said it would review the decision when greater tax and regulatory clarity becomes available.
The situation was also not associated with a credit event, default or deterioration common to all six portfolios. The issue raised by XP concerns taxation when ETF shares are sold at a profit and the brokerage firm’s responsibility for withholding the tax.
Taxation depends on the portfolio, not the investor’s holding period
Fixed-income ETFs follow their own income-tax schedule. The tax rate does not decline according to how long the investor holds the shares, unlike the regressive system applied to bank deposit certificates and other traditional fixed-income investments.
The applicable rate depends on the portfolio’s average repricing period:
- 25% for an average period of up to 180 days;
- 20% for an average period between 181 and 720 days;
- 15% for an average period longer than 720 days.
In practice, all investors in the same ETF are subject to the rate corresponding to the portfolio’s average period, regardless of whether they sell their shares after a few days or several years.
The question is relevant because the six ETFs invest primarily in securities linked to the CDI or in structures combining floating-rate private credit with other assets. Because the CDI and Selic rates change daily, the debate is whether the instruments should be considered to have a one-day repricing period, leading to a 25% rate, or whether their contractual maturities should apply. Many of those maturities exceed 720 days and would qualify for the 15% rate.
The Treasury Selic case created a precedent
The debate is related to the previous interpretation adopted for ETFs holding Brazilian Treasury Selic securities. In 2024, a Brazilian Treasury information note concluded that these securities had a one-day repricing period because their remuneration follows the Selic rate daily.
This interpretation subjected ETFs consisting entirely of Treasury Selic securities to a 25% rate, regardless of the bonds’ final maturities. Some asset managers subsequently developed hybrid indexes that combined floating-rate government bonds with a portion of longer-maturity inflation-linked securities to increase the portfolio’s average period.
The current question is whether the same interpretation will apply to private securities linked to the CDI or whether the contractual maturities of debentures and Financial Notes will be considered.
Anbima supports a 15% rate for long portfolios
Anbima says its working group has reached a consensus that private-credit ETFs should be subject to a 15% rate when the securities in the portfolio have repricing periods longer than 720 days.
The association argues that ETFs should receive tax treatment equivalent to that of their underlying assets. According to Anbima, the proposal is not intended to create a tax benefit but to ensure consistency between investing directly in the securities and accessing the same market through an exchange-traded fund. The position has been submitted to the government and remains under discussion.
Anbima also emphasized the role of these products in broadening access to private credit. ETFs allow investors to purchase a diversified portfolio through a single share while potentially contributing to liquidity, price formation and the development of the secondary market.
Until the relevant authorities issue a definitive position, investors need to review the tax information adopted by the fund, brokerage firm and administrator. The debate affects the investment’s net return but does not directly change the remuneration, credit risk or mark-to-market valuation of the portfolio’s securities.
The Selic rate supports portfolio carry in 2026
The five ETFs included in the DEX PRO database generated returns close to 10% in 2026. MARG11 led the group at 10.76%, followed by NLFA11 at 10.31%, LFIN11 at 10.29%, DEBB11 at 10.28% and GICP11 at 9.74%. Over the latest 30-day period, returns ranged from 0.80% to 1.06%.
Performance was supported primarily by the carry generated by CDI-linked portfolios. In September, the Selic rate stood at 13.75% per year, while the CDI remained close to that level following a gradual decline in interest rates during 2026.
Because debentures and Financial Notes generally pay the CDI or DI rate plus a spread, the funds benefited from still-elevated short-term interest rates. In addition to this carry, performance can be affected by changes in credit spreads, shifts in perceptions of issuer risk and the mark-to-market valuation of individual securities.
The portfolios are not equivalent. NLFA11 and LFIN11 focus on Financial Notes issued by banks. DEBB11, MARG11 and GICP11 invest in corporate debentures but apply different filters and levels of interest-rate and spread sensitivity. AMAB11 combines private credit, securities associated with development in the Amazon region and an allocation to long-term inflation-linked government bonds.
DEBB11: +1.06% over one month and +10.28% in 2026
DEBB11 returned 1.06% over the latest 30 days and 10.28% in 2026. It recorded the highest monthly return among the five ETFs in the database.
The ETF tracks the Teva Debentures DI Index, which is composed of corporate debentures linked to the CDI plus a spread. The methodology requires minimum issue size, secondary-market liquidity and recurring trading activity. The maximum weight is limited to 4.5% per issuer, and the portfolio is rebalanced monthly.
The portfolio held approximately 200 debentures. Major securities included issues from B3, Cielo, Suzano, Energisa, Sabesp, Eletrobras, Eurofarma, Transportadora Associada de Gás and Claro. The fund also maintained a portion of its portfolio in floating-rate government bonds.
Broad diversification reduced the impact of any individual issuer. The accumulated return reflected the CDI carry and the spreads contracted through the debentures, while the monthly variation also incorporated mark-to-market changes. The methodology prioritizes regularly traded securities, which is relevant to portfolio replication and the management of ETF inflows and outflows.
LFIN11: +1.05% over one month and +10.29% in 2026
LFIN11 advanced 1.05% over the latest 30 days and accumulated 10.29% in 2026. Its annual performance remained close to the CDI, consistent with a strategy based on floating-rate Financial Notes plus a bank-credit premium.
The ETF tracks the Teva LFIN DI Index, composed of senior Financial Notes linked to the DI rate or paying a percentage of that rate. Eligible securities must be issued by financial institutions classified in the Brazilian Central Bank’s S1, S2 or S3 segments, have defined maturities and make no intermediate coupon or principal payments.
Major securities included issues from Santander, BTG Pactual, Caixa Econômica Federal, Bradesco, Safra, XP, Citibank and Goldman Sachs. At issuer level, the index’s largest weights were in Itaú, BTG Pactual, Caixa, Bradesco and Safra.
The methodology seeks to hold securities until maturity, reducing portfolio turnover. The index had a carry spread of DI plus 0.44%, with thousands of instruments distributed among dozens of issuers. Performance reflected this additional premium and the high CDI rate, with limited volatility compared with longer-duration debenture strategies.
NLFA11: +1.00% over one month and +10.31% in 2026
NLFA11 returned 1.00% over one month and 10.31% in 2026. The product seeks to track Anbima’s Financial Notes Index, offering a diversified bank-credit portfolio primarily composed of high-grade issuers.
The portfolio consisted of senior Financial Notes issued by banks and other financial institutions. In September, 55.9% of the exposure was allocated to S1 issuers, 26.6% to S2, 15.4% to S3 and 2.1% to S4.
Issuers included Banco do Brasil, Bradesco, BTG Pactual, Santander, Nubank, Safra, Sicredi, Votorantim, XP, ABC Brasil, Daycoval, Porto Seguro, Stone and financial institutions associated with vehicle manufacturers.
The monthly return was slightly below those of DEBB11 and LFIN11, but the difference amounted to only a few basis points. The annual result remained close to the other floating-rate products, reflecting the CDI and the credit premiums offered by Financial Notes.
MARG11: +0.95% over one month and +10.76% in 2026
MARG11 advanced 0.95% over the latest 30 days and led the group in 2026 with a 10.76% gain.
The ETF tracks B3’s Ultra High-Grade DI Debentures Index. The portfolio selects debentures paying the DI rate plus a spread that meet quality requirements and are eligible as collateral within B3’s market infrastructure.
The largest positions included issues from ISA Energia, Auren, Suzano, Vibra Energia, Assaí, Porto, Iochpe-Maxion, Marfrig, Sabesp and Localiza Rent a Car. The ten largest securities represented a relevant portion of the portfolio, making the fund more concentrated than DEBB11.
The annual return exceeded those of DEBB11 and the Financial Notes ETFs included in the database. The result was consistent with CDI carry plus debenture spreads, although the latest monthly return was below those of some other products in the group. By selecting specific high-quality issues, the portfolio combines floating-rate carry with changes in the credit premiums of those issuers.
GICP11: +0.80% over one month and +9.74% in 2026
GICP11 gained 0.80% over one month and 9.74% in 2026, the lowest returns among the five ETFs in the spreadsheet.
The fund tracks the Teva DI Quality High Beta Debentures Index. The strategy allocates 99% of the portfolio to debentures linked to the DI rate plus a spread, focusing on high-quality, longer-duration securities. The index had a duration of 3.5 years and a carry spread of DI plus 1.23%.
The largest positions included issues from TIM, Rede D’Or, Sabesp, Eletrobras, ISA Energia, Localiza, Aegea, Nova Transportadora do Sudeste, Celg and Suzano. The portfolio held dozens of securities and issuers, reducing individual concentration while preserving meaningful sensitivity to changes in credit spreads.
The credit premium was higher than that of LFIN11’s Financial Notes, but the longer duration also increased the portfolio’s mark-to-market sensitivity. During 2026, the fund had months of strong performance as well as periods when it underperformed the CDI. The 0.80% return over the latest 30 days and 9.74% annual result reflected this combination of higher carry and greater debenture-price variation.
AMAB11 combines private credit and long-term inflation-linked bonds
AMAB11 began trading in August 2026 and therefore does not have the same history as the other products. From launch through September, the ETF generated a return of approximately 1.1%, divided between about 0.5% in August and 0.6% in September. The available period is still too short for a direct comparison with the full-year returns of the other five ETFs.
The product tracks the Teva Amazonia Bonds Index, composed of bonds and debentures associated with development in the Amazon region, as well as government securities. The methodology maintains 10% in the Teva Ultra-Long Inflation-Linked Treasury Index and allocates the remainder among ABIG-aligned bonds and debentures from selected sectors.
The August portfolio allocated 9.76% to Brazil’s inflation-linked Treasury bond maturing in 2060. Other positions included issues related to energy, sanitation, telecommunications and healthcare, including securities from Equatorial, ISA Energia, Claro, Dasa, Aegea, Taesa, Hapvida, Smart Fit and Rede D’Or.
Exposure to the 2060 inflation-linked government bond differentiates AMAB11’s behavior. In addition to floating-rate carry and credit spreads, the ETF is sensitive to long-term real interest rates. During its first months of trading, this structure contributed to a return below the CDI, although the available record covers only part of August and September.
The index was designed with an average repricing period close to 760 days, above the 720-day threshold associated with the 15% tax rate. The methodology and its tax treatment, however, form part of the debate that led XP to temporarily suspend new investments.
Exposure chart
| ETF | Main exposure | Portfolio characteristic |
|---|---|---|
| DEBB11 | Corporate debentures | Broad diversification and liquidity requirements |
| LFIN11 | Financial Notes | Banks classified in the Central Bank’s S1, S2 and S3 segments |
| NLFA11 | Financial Notes | Greater concentration in S1 financial institutions |
| MARG11 | Corporate debentures | High-quality issues eligible as collateral within B3’s infrastructure |
| GICP11 | Corporate debentures | Longer duration and greater sensitivity to credit-spread movements |
| AMAB11 | Thematic private credit and inflation-linked government bonds | Amazon development exposure and long-term inflation sensitivity |
Tax uncertainty does not eliminate differences among the products
XP grouped the six ETFs in its decision because they invest in private credit or fixed-income structures using CDI-linked securities. This does not mean their portfolios are identical.
NLFA11 and LFIN11 concentrate bank-credit risk through Financial Notes. DEBB11 offers the broadest diversification among liquid corporate debentures. MARG11 applies stricter quality and eligibility filters. GICP11 assumes longer duration to increase exposure to credit spreads. AMAB11 combines thematic private credit with a relevant allocation to long-term inflation-linked bonds.
These differences help explain the dispersion in returns. Over the latest 30 days, the five ETFs in the database gained between 0.80% and 1.06%. In 2026, returns ranged from 9.74% to 10.76%. The elevated CDI supported all the strategies, but credit-spread movements, duration, issuers and index criteria produced different outcomes.
Taxation should be considered when evaluating net returns, but it does not replace portfolio analysis. Investors also need to assess credit risk, concentration, bond liquidity, duration, spread, management fees and the ETF’s adherence to its underlying index.
XP’s decision increased attention on an issue that still requires clarification. Until a definitive interpretation emerges, the most accurate reading is that there is disagreement over the tax calculation, rather than a general suspension of private-credit ETFs or a joint deterioration of their underlying assets.
