Brazil has enacted Provisional Measure No. 1.262 of October 3, 2024, and Normative Instruction No. 2.228 of October 3, 2024, to introduce an Additional Social Contribution to Net Profit (CSLL). This initiative aims to comply with the requirements of a Qualified Domestic Minimum Top-up Tax (QDMTT) by the Pillar Two global minimum tax framework.
Normative Instruction No. 2.228 establishes guidelines for the Social Contribution on Net Income, aligning Brazilian legislation with the Global Rules to Combat Tax Base Erosion.
The Additional CSLL percentage is calculated as 15% minus the effective tax rate of Brazilian entities belonging to MNE groups with annual consolidated revenues of at least EUR 750 million in two of the last four fiscal years.
The Provisional Measure and Normative Instruction went into force on 3 October 2025, and is applicable starting 1 January 2025. The Provisional Measure requires approval from the National Congress to remain valid and may be amended.
