Pular para o conteúdo
← Back to Skalablog

Published article

Does GPOS11 ETF Avoid the 20% PMR Tax?

Products & Business

GPOS11 ETF keeps a PMR near 885 days, more than 720, and its promoter says the index would not have dropped below that level between 2016 and 2026. The number matters because a fund whose PMR falls below 720 days moves from the 15% to the 20% tax bracket on its whole gain and the investor does not control that.

What GPOS11 ETF Is and How Its 885-Day PMR Works

GPOS11 ETF is a Brazilian fixed-income ETF listed on B3 and managed by Grão, the asset manager linked to the Primo group. It targets a portfolio PMR (prazo médio de repactuação, or average repricing term) of close to 885 days. Because Brazil's fund tax rule raises the rate from 15% to 20% once PMR falls below 720 days, staying above that line is the fund's central design goal.

The structure is a barbell, not a ladder of short bonds. Roughly 89% sits in the five shortest Tesouro Selic (LFT) maturities, weighted equally and spread between 2026 and 2029, while approximately 11% sits in a single NTN-B, the inflation-linked Tesouro IPCA+, maturing in 2060. The long NTN-B pulls the average repricing term upward; the short LFTs supply liquidity and keep the portfolio close to the Selic rate. Because the weight of the long NTN-B is re-scaled at each month end, the blend can aim for 885 days rather than letting the average drift with the market.

BTG Pactual acts as market maker for the fund, which means a bank quotes buy and sell prices through the trading day so a new ETF with a small holder base is not left without a counterparty. Without a market maker, an ETF can trade at a wide spread between its net asset value and its exchange price, and a retail investor pays that spread on entry and exit. A continuous two-sided quote is what keeps that spread from widening on a thinly traded book.

The fee is 0.1% per year, covering administration, management and custody, according to the promoter's published material. For comparison, a traditional bank-distributed fixed-income fund often charges between 1% and 1.5% a year and may also apply a performance fee.

GPOS11 at a Glance

FeatureGPOS11Typical bank fixed-income fund
Target PMR885 daysNot disclosed
Tax rate on income15% above 720 days15% to 20%
Annual fee0.1%1% to 1.5%
Performance feeNone statedSometimes applied
Market makerBTG PactualNot applicable

FAQ

  • What is PMR in GPOS11? It is the weighted average of the dates on which the bonds in the portfolio reset their rate. GPOS11 targets roughly 885 days.
  • Why does 720 days matter for the tax? Under Brazil's fund tax rule, falling below 720 days of PMR raises the tax on the fund's income from 15% to 20%.
  • How does GPOS11 keep its PMR near 885 days? Roughly 89% sits in five short Tesouro Selic (LFT) maturities, about 11% in one long NTN-B maturing in 2060, and the long NTN-B weight is re-scaled at each month end.
  • What does the market maker do? BTG Pactual quotes buy and sell prices through the trading day, so a small holder base is not left without a counterparty and the NAV-to-price spread stays narrow.
  • What does GPOS11 charge? 0.1% per year covering administration, management and custody, against 1% to 1.5% plus possible performance fees at a traditional bank-distributed fund.

Brazil's 720-Day PMR Rule and the 20% Tax Bracket

The PMR rule ties the tax rate on Brazilian fixed-income funds to the portfolio's weighted average repricing term. When that average sits below 720 days for the relevant period, the tax on the fund's gain rises from 15% to 20%. The rule exists to stop funds that look long-term on paper from behaving like short-term parking, since the long-term tax benefit is meant to reward duration, not liquidity.

The investor does not control the PMR. The manager does. If the manager lets the average slip below 720 days, even for one day inside the measurement window, the fund's gain for that period is taxed at the higher rate. A short-only Tesouro Selic fund or a plain post-fixed fund is the prime candidate for that slip, because every bond it holds has a short repricing date and there is nothing in the portfolio to pull the average up.

The arithmetic is small in percentage points and large in reais. Take R$ 100,000 invested in a fund that earned 20% over a period, or R$ 20,000 of profit. At 15% tax the bill is R$ 3,000 and the investor keeps R$ 17,000. At 20% tax the bill is R$ 4,000 and the investor keeps R$ 16,000. Same fund, same return, R$ 1,000 less in the investor's account.

That is the trade the ETF is trying to remove. The Grão/Group Primo back test for the index ran from June 2016 to the publication of the video and covered more than 2,500 trading days, according to the promoter. The result reported in the video was a PMR that never fell below 720 days during that stretch.

Frequently Asked Questions

  • Who decides whether a fund stays above the 720-day PMR threshold? The manager does. Investors cannot steer the weighted average repricing term, so the 15% or 20% outcome depends on how the portfolio is built and maintained.
  • Does a single day below 720 days change the tax rate? Yes. If the average slips below 720 days even for one day inside the measurement window, the gain for that period is taxed at 20% rather than 15%.
  • What does the 20% bracket cost on R$ 100,000? On R$ 20,000 of profit, the bill is R$ 4,000 at 20% versus R$ 3,000 at 15%, leaving the investor R$ 16,000 instead of R$ 17,000, or R$ 1,000 less.
  • Which funds are most exposed to the higher rate? Short-only Tesouro Selic funds and plain post-fixed funds, since each bond they hold carries a short repricing date and nothing in the portfolio lifts the average.
  • What did the Grão/Group Primo back test show? The promoter reported a PMR that never fell below 720 days from June 2016 to the publication of the video, a stretch covering more than 2,500 trading days.

Index Composition: LFTs and a Long NTN-B

The short LFT sleeve

The short sleeve of the GPOS11 index sits in the five shortest LFTs available from the Brazilian Treasury, weighted equally rather than by market value. LFTs are floating-rate bonds tied to the Selic rate by construction, so price volatility on that sleeve is small in the short-dated portion. Concentrating on the front of the curve keeps the portfolio close to the daily Selic accrual and keeps the LFT maturities short enough that the fund remains liquid when a holder leaves.

The long NTN-B sleeve

The long sleeve is an inflation-linked NTN-B due in 2060, paying a real rate of more than 7% a year at the level reported in the video. NTN-Bs reset their coupon structure on a long schedule, so their repricing term is far above 720 days; a small weight allows the fund to lift its average PMR without exposing the portfolio to large duration swings. The monthly weight adjustment is where the engineering lives: the manager changes only the NTN-B slice, keeping the average PMR aimed at around 885 days.

The rebalancing effect

Re-scaling the long slice at each month end is a mechanical way to hold a target average repricing term. It does not give the investor any promise about the future: the weights that keep the PMR at 885 days depend on the current LFT ladder and the current NTN-B duration, and those change with new Treasury auctions and with the shape of the curve.

Back-test Numbers: CDI Returns, Volatility and Tax Outcome

The promoter's back test reported the index returning an average of about 9.53% a year from June 2016 to 2026, compared with roughly 9.37% for the CDI over the same period. Both figures come from the manager behind the ETF, not from an independent measurement, and the CDI is a reference rate rather than a tradable portfolio with costs.

The back test also reported positive returns in 100% of the rolling 12-month windows in that range. That kind of claim needs its date coverage, net-of-fee assumption and rebalancing rules to be read alongside it; a back test that re-scales a long bond position every month can look smoother than the live product if the rule cannot be executed at the assumed price. Prospective investors should ask the manager for the full methodology before treating a promoter time series as a live track record.

The volatility comparison the promoter gave was small in absolute terms. A pure Tesouro Selic fund would swing by roughly R$ 800 a year on a R$ 100,000 holding, while the NTN-B slice would push that swing toward R$ 900 a year. On the same R$ 100,000 base, that difference is close to 0.1 percentage point, which is why the promoter calls the extra NTN-B risk almost irrelevant next to a 5-percentage-point tax saving.

GPOS11 ETF Compared With CDs, Selic Funds and Fixed-Income Peers

The table below compares the main routes a Brazilian retail investor uses for short-term fixed income on the dimensions that change the decision: what controls the repricing term, how tax is set, fee level and whether the investor needs a brokerage account.

RoutePMR controlFund tax levelFee level (reported)Access
GPOS11 ETFManager re-weights NTN-B monthly, target around 885 days15% if PMR stays above 720 days0.1% a yearBrokerage and B3
Tesouro Selic directInvestor holds an LFT; no fundNot a fund; individual Treasury taxNo management feeTesouro Direto platform
Plain Tesouro Selic fundShort LFTs only, PMR near the front of the curveCan reach 20% if PMR falls below 720 daysCommonly 1%-1.5% a year at banksBank or brokerage fund platform
CDB at a bankInvestor holds a bank deposit; no fundNot a fund; CDB tax follows the deposit tableNo explicit management fee; bank spread embeddedBank or brokerage
Existing short fixed-income ETFManager's call; investor cannot influence itDepends on the PMR the manager holdsVaries by productBrokerage and B3

Tax Treatment, Fee and the 2026 Regulatory Context

The fund-level tax rule is not an investor-level table. Brazil taxes the fund on its income, and the rate depends on the PMR. An ETF is a fund for this purpose. An individual CDB or Tesouro Direto position is not, and its tax follows the deposit or Treasury table, not the 720-day PMR line. That distinction is the hinge of the GPOS11 proposal.

The relevant law for the fund level rule is Lei nº 13.043/2014, which sets out the 720-day dividing line for the reduced rate on fixed-income investment funds. It is a statute, not a temporary regulation, so the architectural question is whether a manager can keep a portfolio's weighted average repricing term above 720 days through a full market cycle. The promoter's answer is a monthly mechanical re-weight, and the answer is only as good as the next rebalance.

The fund sits inside an asset manager, Grão, whose material reports more than 30,000 registered clients, more than 16,000 shareholders in a sibling ETF, and more than R$ 2.5 billion under custody. Those are promoter-reported figures and they describe the manager, not the return of GPOS11 itself; a large client base is not evidence that the PMR strategy will perform in the next cycle.

Does GPOS11 ETF Have Liquidity, and Who Is It For?

Liquidity rests on BTG Pactual acting as designated market maker on B3, quoting prices through the trading day. That commitment is not the same as a guaranteed tight spread, so the practical test for a retail investor is the bid-ask spread at the moment of the order, not the bank's presence alone.

The product is designed for an investor who is already parking money in short-term fixed income: a Tesouro Selic holding, a CDB with daily liquidity, or a bank fixed-income fund. If the money is genuinely parked for months, the PMR question is minor. If the money is meant to sit for years as portfolio cash, a PMR that stays above 720 days can change the after-tax total by more than the fee difference between a bank fund and an ETF.

The strategy is not a substitute for a risk asset. GPOS11 does not hold shares, credit or FX; it holds Treasury bonds. It also does not fully remove market risk: the NTN-B due in 2060 can move in price when real rates change, and the fund is a 2060-dated bond inside a liquid wrapper. Investors should treat it as one qualified source on the mechanical details of the PMR rule, given that the promoter is also the seller of the product.

FAQ

  • Does GPOS11 have a market maker? Yes, BTG Pactual acts as designated market maker on B3, quoting prices through the trading day.
  • Does a market maker guarantee a tight spread? No, it guarantees quoting, not a specific spread; check the bid-ask spread at order time.
  • Who is GPOS11 designed for? Investors already parking money in short-term fixed income, such as Tesouro Selic, a daily-liquidity CDB, or a bank fixed-income fund.
  • Does GPOS11 remove market risk? No, it holds Treasury bonds, and the NTN-B due in 2060 can move in price when real rates change.
  • Is GPOS11 a substitute for a risk asset? No, it holds no shares, credit or FX, only Treasury bonds.

FAQ

  • What is the PMR of GPOS11 ETF? The fund's index targets an average repricing term close to 885 days, above the 720-day level that would raise tax from 15% to 20%. The actual PMR is published in fund documents and can differ from the target.

Source video