The consultation period will conclude on 14 September 2025.
Brazil’s Federal Revenue Service (RFB) has initiated a public consultation to discuss proposed amendments to Normative Instruction RFB No. 2.228 of 3 October 2024, which governs the Additional Social Contribution on Net Profit (CSLL), established by Provisional Measure No. 1.262 (3 October 2024) and Law No. 15.079 (27 December 2024).
The CSLL surcharge is part of Brazil’s legislative adjustments to the Global Anti-Base Erosion (GloBE) Rules, enabling the country to take priority in collecting the supplementary tax owed by multinational groups that fall within scope due to their low level of taxation in Brazil.
The Additional CSLL aims to align with the Pillar Two global minimum tax rules as a qualified domestic minimum top-up tax (QDMTT). The regulations are being updated to ensure the Additional CSLL qualifies as a QDMTT, incorporating administrative guidance from June 2024 and January 2025. Key updates address fiscal year alignment, accounting standards for non-real-profit taxpayers, business combinations, hybrid/transparent entity classification, and tax attribution.
The Brazilian Federal Revenue Service’s Special Secretariat is committed to ensuring legal certainty and safeguarding the national tax base by continually reviewing and refining regulations to implement the GloBE Rules into domestic law properly.
Most changes will take effect on 1 January 2025, with some deferred to 2026 but optionally applicable from 2025.
The consultation period will run from today, 29 August, until 14 September 2025.
