Brazil’s Federal Revenue Service has published its first Q&A guide on the Additional Social Contribution on Net Profits, providing practical guidance on the QDMTT, Pillar Two scope, effective tax rate calculations, refundable tax credits, and compliance requirements.
Brazil’s Federal Revenue Service (RFB) published the first edition of its Q&As guide on the Additional Social Contribution on Net Profits (CSLL) on 2 October 2026. The guide provides practical guidance on Brazil’s recently implemented qualified domestic minimum top-up tax (QDMTT), which implements the global minimum tax framework under Pillar Two of the OECD/G20 BEPS 2.0 project.
This publication provides operational and conceptual guidance based on Law No. 15,079/2024 and Normative Instruction RFB No. 2,228/2024 to assist both taxpayers and tax authorities. It clarifies key definitions, including constituent entities, multinational enterprise groups, excluded entities, and permanent establishments.
Pillar Two implementation & scope
Brazil’s CSLL implements the BEPS 2.0 Pillar Two GloBE rules by establishing a 15% minimum effective tax rate for qualifying multinational enterprise (MNE) groups. The rules apply to Brazilian Constituent Entities of groups with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding fiscal years.
The threshold is converted into BRL using the ECB’s average December exchange rate and adjusted proportionally for fiscal years shorter than 12 months.
The rules cover Constituent Entities and permanent establishments, while certain entities such as government bodies, non-profits, pension funds, and investment funds acting as ultimate parent entities are excluded.
Entities not ordinarily subject to CSLL may still be covered by the additional contribution and must obtain a CNPJ registration.
Regulatory framework & hierarchy
The manual consolidates guidance under Law No. 15,079/2024 and Normative Instruction RFB No. 2,228/2024, while also referring to OECD GloBE materials, including the Model Rules, Commentary, and Agreed Administrative Guidance, as supplementary interpretive sources.
However, the Q&A is informational only, and the applicable statutory and regulatory provisions prevail in cases of conflicting interpretations.
Practical scope: Technical calculations & definitions
The guide provides rules for calculating the jurisdictional effective tax rate (ETR) by dividing Adjusted Covered Taxes by GloBE Income or Loss. It distinguishes between qualified refundable tax credits, which are treated as GloBE income if refundable within four years, and non-qualified credits, which reduce current tax expense.
It also clarifies three fiscal year concepts: the fiscal year of the Constituent Entity, the Ultimate Parent Entity’s consolidated fiscal year, and the jurisdictional fiscal year applicable to Brazilian entities.
Compliance roadmap
The guide draws on actual taxpayer inquiries, internal technical procedures, and the practical experience of Receita Federal’s Cosit, Cotin, and Ditin units. It provides practical guidance for corporate accounting and tax teams on determining the scope of MNE groups, adjusting financial results to calculate GloBE Income, identifying covered taxes, applying safe harbours, and meeting the required filing obligations.
