Brazil's tax authority seeks stakeholder input on updated rules for the CSLL Surcharge affecting multinational groups, with submissions accepted until 3 May 2026 as part of the country's alignment with global minimum tax standards.
Brazil’s tax authority, the Federal Revenue Service (RFB) has launched a public consultation process on 17 April 2026 to amend Normative Instruction RFB No. 2,228/2024, which governs the CSLL Surcharge.
Interested parties can submit their feedback between 17 April 2026 and 3 May 2026.
The CSLL Surcharge was introduced through Provisional Measure No. 1,262 of 3 October 2024 and later codified in Law No. 15,079 of 27 December 2024. This measure forms part of Brazil’s efforts to align with the Global Anti-Base Erosion (GloBE) Rules, enabling the country to collect supplementary taxes from multinational business groups operating in Brazil that benefit from low effective tax rates.
The consultation focuses on incorporating guidance from the OECD Inclusive Framework’s January 2026 Administrative Guidance, specifically the Globe Simplifying Rule for Substance-Based Tax Incentives (RSGIF). The proposed amendments will introduce new provisions covering:
- Qualified tax incentives, including expenditure-based and production-based incentives
- Qualified refundable tax credits
- Substance limits for tax incentives
- Rules for calculating expenses incurred and quantities produced
These changes will take effect from 1 January 2026, ensuring the CSLL Surcharge maintains its status as a Qualified Minimum Domestic Supplementary Tax (QDMTT).
Companies, academic institutions, and other stakeholders can submit their contributions via email to cotin.df.cosit@rfb.gov.br, preferably in PDF format.
