Brazil updated CSLL rules to align with Pillar 2 QDMTT, retroactively effective from 1 January 2025.
Brazil’s Federal Revenue Service (RFB) has issued Normative Instruction No. 2.282 on 2 October 2025, amending Normative Instruction No. 2.228 of 3 October 2024, which outlines that Additional Social Contribution on Net Profit (CSLL) is designed to function as a qualified domestic minimum top-up tax (QDMTT) under the Pillar 2 global minimum tax framework.
To ensure compliance with QDMTT requirements, the new amendments incorporate updates based on the OECD administrative guidance issued in June 2024 and January 2025. The revised text also introduces drafting adjustments to improve clarity and consistency in the application of the rules.
Key areas addressed by the amendments include fiscal year alignment for constituent entities, accounting standards applicable to non-real-profit taxpayers, the treatment of business combinations, the classification of hybrid and transparent entities, and the allocation of current covered and deferred taxes.
Most provisions take effect from 1 January 2025. However, some rules will apply from 1 January 2026, with the option for multinational enterprise (MNE) groups to adopt them voluntarily from 1 January 2025.
Earlier, Brazil issued Normative Instruction RFB No. 2.259/2025, updating rules for the Additional CSLL aligned with Pillar Two. The measure clarified the fiscal year for calculation and lowered penalty caps for late or inaccurate filings to BRL 5 million. It took effect on 26 March 2025.
