Brazil’s RFB has amended the CSLL rules to introduce a substance-based tax incentive simplification rule and extend the transitional simplification regime under the OECD Inclusive Framework’s global minimum tax framework.
The Brazilian Federal Revenue Service (RFB) announced, on 1 October 2026, the publication of Normative Instruction RFB No. 2342 on 15 September 2026. The amendment introduces two main regulatory updates. The first establishes the Globe Simplifying Rule for Substance-Based Tax Incentives (RSGIF). The second extends the applicability period for the existing Globe Transition Simplifying Rule (RSGT).
The instruction amends RFB Instruction No. 2228/2024 to implement provisions from the OECD Inclusive Framework’s Side-by-Side Package, approved in January 2026. The changes align Brazil’s CSLL (Social Contribution on Net Profit) surcharge with international standards, as required by Law No. 15,079 of 3 October 2024.
New substance-based tax incentive rule
The RSGIF permits multinational corporate groups to classify qualified tax incentives as additions to Adjusted Covered Taxes. This treatment increases the effective tax rate and can reduce the Additional Social Contribution on Net Profit (AdCSLL) owed in a given jurisdiction.
A tax incentive qualifies as an IFQ (Qualified Tax Incentive) under this rule if it meets one of two conditions. First, the incentive must be linked to expenses the company incurs. Second, it must directly relate to production volume. In both cases, the incentive must reduce a tax liability that falls within the scope of Globe Rules.
The RFB specified that certain incentives do not qualify. These include incentives that reduce taxes outside the Globe Rules scope, those linked exclusively to already-excluded income, subsidies and general grants, incentives not available to all eligible companies, and those granted through government discretion rather than legal entitlement.
The amount added to Adjusted Covered Taxes cannot exceed the Substance Limit, which incorporates payroll and physical asset values in its calculation. Adoption of the RSGIF is optional and operates on a one-year election basis. The rule applies to fiscal years beginning on or after 1 January 2026.
Extended transition rule
The amendment also extends the Globe Transition Simplifying Rule (RSGT) originally established in RFB Instruction No. 2228/2024. The extended rule now applies to fiscal years beginning on or before 31 December 2027, excluding fiscal years that end after 30 June 2029.
