Brazil has issued Normative Instruction RFB No. 2.259 of 24 March 2025, which amends the regulations for the Additional Social Contribution on Net Profit (CSLL) contained in Normative Instruction RFB No. 2,228 of 3 October 2024.
The Additional CSLL aligns with Pillar 2 global minimum tax rules as a qualified domestic minimum top-up tax (QDMTT).
Initially introduced as a provisional measure in October 2024, it was formally enacted through Law No. 15.079 of 27 December 2024 and took effect on 1 January 2025. The amendments introduced by Normative Instruction RFB No. 2.259 clarify the fiscal year for calculating the Additional CSLL and revise penalties.
Failed or late submissions now incur a penalty of 0.2% of total fiscal year revenue per month, capped at 10% or BRL 5 million (down from BRL 10 million).
The amendment law also set the cap of the maximum penalty, which previously lacked. For providing inaccurate, incorrect, or omitted information, the penalty is 5% of the affected amount, with a minimum of BRL 20,000 and a maximum of BRL 5 million.
Normative Instruction RFB No. 2.259 took effect on 26 March 2025.
Earlier, Brazil enacted Provisional Measure No. 1.262 and Normative Instruction No. 2.228 of 3 October 2024, introducing an Additional Social Contribution to Net Profit (CSLL). This aligns with the Qualified Domestic Minimum Top-up Tax (QDMTT) under the Pillar Two global minimum tax framework. The Provisional Measure and Normative Instruction took effect on 3 October 2025 and applied from 1 January 2025.
