Brazil's Federal Revenue Service announced on 8 July 2026 that multinational business groups with annual revenue of EUR 750 million or more must pay an additional Corporate Social Contribution on Net Profit (CSLL) by 31 July 2026 for fiscal years ending 31 December 2025, enforcing a 15% minimum tax rate under the OECD's Global Rules against Base Erosion.
Brazil’s Federal Revenue Service (RFB) announced, on 8 July 2026, that it has introduced an additional Corporate Social Contribution on Net Profit (CSLL) to enforce a 15% minimum tax rate on multinational companies.
The CSLL Surcharge aligns with the OECD’s Global Rules against Base Erosion (GloBE Rules) and specifically implements the Qualified Domestic Minimum Top-up Tax (QDMTT).
Who pays and when
The tax applies to multinational groups that earned EUR 750 million or more in annual revenue during at least two of the past four fiscal years. For a group with a fiscal year ending 31 December 2025, the surcharge payment is due by 31 July 2026.
Each subsidiary can pay separately using DARF code 1809-01, or a single entity can handle centralised payment using code 1809-02. Both methods remain valid—the group chooses which approach works operationally.
Reporting obligations
Two separate deadlines exist for tax authorities.
First, companies must report the tax amount in DCTFWeb during the Assessment Period covering the sixth month after their fiscal year closes. For groups ending 31 December 2025, this means submitting information for the June 2026 tax period by 31 July 2026.
The timeline shifts for different fiscal years.
A group ending 31 March 2026 reports for the September 2026 tax period by 30 October 2026. Always count forward six months from your fiscal year-end to find your reporting window.
The detailed calculation submission
Brazil’s Federal Revenue Service is still building the ancillary obligation form that groups will use to provide calculation details.
The first submission window opens 18 months after a fiscal year closes. Groups with a 31 December 2025 year-end won’t submit this data before 30 June 2027. This gives companies time to organise their calculations and supporting documentation.
Earlier, Brazil’s Federal Revenue Service (RFB) amended the rules governing the Additional Social Contribution on Net Profit (CSLL) surcharge, strengthening the country’s implementation of the OECD’s GloBE Rules and providing multinational groups with clearer compliance guidance.
