  Context. Brown dwarf companions to stars at separations of a few AU or less
are rare objects, and none have been found so far around early-type M dwarfs
M0V-M5V). With GJ 1046 (M2.5V), a strong candidate for such a system with a
separation of 0.42 AU is presented.
  Aims. We aim at constraining the mass of the companion in order to decide
whether it is a brown dwarf or a low-mass star.
  Methods. We employed precision RV measurements to determine the orbital
parameters and the minimum companion mass. We then derived an upper limit to
the companion mass from the lack of disturbances of the RV measurements by a
secondary spectrum. An even tighter upper limit is subsequently established by
combining the RV-derived orbital parameters with the recent new version of the
Hipparcos Intermediate Astrometric Data.
  Results. For the mass of the companion, we derive m>26.9 MJup from the RV
data. Based on the RV data alone, the probability that the companion exceeds
the stellar mass threshold is just 6.2%. The absence of effects from the
secondary spectrum lets us constrain the companion mass to m <229 MJup. The
combination of RV and Hipparcos data yields a 3sigma upper mass limit to the
companion mass of 112 MJup with a formal optimum value at m=47.2 MJup. From the
combination of RV and astrometric data, the chance probability that the
companion is a star is 2.9%.
  Conclusions. We have found a low-mass, close companion to an early-type M
dwarf. While the most likely interpretation of this object is that it is a
brown dwarf, a low-mass stellar companion is not fully excluded.
