The President of Brazil, Luiz Inácio Lula da Silva, enacted Bill No. 3,817/24, which is now known as Law No. 15,079/24, implementing the OECD’s Pillar Two global minimum tax and introduces the global anti-base erosion (GloBE) regulations within Brazil on 30 December 2024.
Law No. 15,079/24 establishes a minimum effective tax rate of 15%. This is achieved through an additional charge on the social contribution on net profits [Contribuição Social sobre o Lucro Líquido (CSLL)].
The newly instituted minimum tax applies to multinational groups that fall under the OECD’s GloBE criteria, specifically those that have reported consolidated annual revenues of at least EUR 750 million in the financial statements of their ultimate parent entity for at least two of the four fiscal years preceding the year in question.
The Law also specifies that the provisions related to the additional CSLL will come into force on 1 January 2025, pending further regulations from the Brazilian tax authorities.
Bill No. 3,817/24 was approved by the Chamber of Deputies on 17 December, and Federal Senate on 18 December, 2024.
