Brazil's Federal Revenue Service (RFB) has set out comprehensive compliance guidance for multinational enterprises on the Additional CSLL, a new surcharge designed to enforce a 15% minimum effective tax rate across group entities.
Brazil’s tax authority, the Federal Revenue Service (RFB), announced on 24 June 2026, that it has issued guidance to Constituent Entities of Multinational Business Groups regarding compliance with the CSLL Additional Tax, including requirements related to tax payments, information reporting through DCTFWeb, and submission of the upcoming ancillary obligation.
The Additional CSLL (Social Contribution on Net Profit) represents Brazil’s adoption of the OECD’s Qualified Domestic Minimum Top-up Tax (QDMTT), part of the global framework against base erosion and profit-shifting. The surcharge targets multinational business groups with consolidated annual revenue of EUR 750 million or more in at least two of the preceding four fiscal years.
Payment arrangements and deadlines
Multinational groups must remit their Additional CSLL by the last business day of the seventh month following fiscal year-end. For entities with a 31 December 2025 fiscal year-end, payment is due by 31 July 2026.
The legislation permits two payment approaches: individual settlements by each group member using DARF code 1809-01, or centralised payment through a single designated entity using code 1809-02. This flexibility allows groups to optimise cash management while maintaining compliance.
Information disclosure in DCTFWeb
Beyond payment, multinational groups must file tax information in DCTFWeb during the assessment period covering the sixth month following their fiscal year close. Groups closing on 31 December 2025 must report in the June 2026 assessment period, with submission required by 31 July 2026—coinciding with the payment deadline.
For groups with alternative fiscal year-ends, deadlines shift accordingly. A group closing on 31 March 2026, for example, reports in September 2026 with a submission deadline of 30 October 2026.
Phased rollout of detailed reporting
The Federal Revenue Service is developing a comprehensive ancillary obligation through which groups will provide all underlying data necessary for the surcharge calculation. Importantly, this obligation will not be imposed earlier than 18 months after the fiscal year closes. Groups with a 31 December 2025 fiscal year-end will not be required to file this detailed report before 30 June 2027, giving them extended preparation time.
The 15% minimum rate framework
The surcharge enforces a uniform minimum effective tax rate of 15% across all constituent entities of a multinational group. This prevents profit-shifting strategies that concentrate earnings in low-tax jurisdictions, ensuring that multinationals operating in Brazil contribute at a rate equivalent to peers in higher-tax environments.
