Brazil's Federal Revenue Service clarified operating rules for the Additional CSLL tax under the OECD's GloBE framework, allowing multinational groups greater flexibility in payment concentration and fiscal year alignment.
Brazil’s Federal Revenue Service (RFB) has published the Normative Instruction RFB No. 2,329 on 19 June 2026, amending the rules governing the Additional Social Contribution on Net Profit (CSLL) surcharge as per Normative Instruction RFB No. 2,228 of 3 October 2024 on 19 June 2026.
The update strengthens Brazil’s implementation of the OECD’s Global Rules against Base Erosion (GloBE Rules) and provides multinational groups with clearer operational guidance for compliance.
The CSLL Surcharge represents Brazil’s implementation of the Qualified Domestic Minimum Top-up Tax (QDMTT), designed to ensure multinational enterprises pay a minimum level of tax on their Brazilian operations. Developed under the OECD’s Inclusive Framework initiative, the GloBE Rules aim to establish a global framework preventing tax base erosion through aggressive planning strategies.
Centralised payment option clarified
The revised rules refine how multinational groups may elect to concentrate CSLL Surcharge payments through a single constituent entity, rather than distributing liabilities across multiple Brazilian entities. Under the amendment to Normative Instruction RFB No. 2,228 (3 October 2024), groups can now designate one entity as the sole taxpayer and responsible party for the entire group’s surcharge obligation.
The Federal Revenue Service (RFB) will distinguish between individual entity payments and centralised payments using separate identification codes on the Federal Revenue Collection Document (DARF). If a group elects centralised payment, the designated entity must apply its specific centralisation code when remitting funds. All payment amounts and calculated tax liabilities will be reported through DCTFWeb, Brazil’s digital tax filing system.
Importantly, multinational groups retain annual flexibility to switch between centralised and other payment allocation methods, allowing them to adapt their structure based on changing circumstances.
Simplifying fiscal year alignment for GloBE compliance
The update addresses practical complications arising from misalignment between jurisdictional fiscal years and Country-by-Country Reporting (CbCR) periods under the GloBE Transition Simplifying Rule (RSGT). Previously, groups faced complexity when their Declared Policy Position (DPP) fiscal year did not align with Brazil’s calendar year.
Groups can now choose either:
- A DPP that closes during Brazil’s fiscal year, or
- A DPP that begins during Brazil’s fiscal year
Consider a multinational with a July-to-June fiscal year operating in Brazil (January-to-December jurisdiction). For the 2025 fiscal year, the group may elect to use either the DPP ending 30 June 2025 or the one beginning 1 July 2025. This flexibility eliminates the need to consolidate data from multiple declarations, streamlining compliance and reducing administrative burden.
Advancing tax transparency
This refinement reflects Brazil’s continued commitment to aligning domestic regulations with international tax transparency standards while reducing administrative complexity for multinationals operating in the country. The amendments increase legal certainty and support Brazil’s role as a participant in the OECD’s efforts to create a more equitable global tax environment.
