The OECD has recognised Brazil’s additional social contribution on net profits (CSLL) as a qualified domestic minimum top-up tax (QDMTT) meeting the safe harbour criteria.
The OECD officially recognised Brazil’s additional social contribution on net profits (CSLL), introduced by Law No. 15. 079/2024 on 18 August 2025, as a qualified domestic minimum top-up tax (QDMTT) meeting the QDMTT safe harbour criteria, effective 1 January 2025.
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.
Earlier, Brazil 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 Two global minimum tax rules as QDMTT.
This recognition aligns Brazil with the global Pillar Two framework, addressing prior concerns about OECD standard compliance.
For multinational groups operating in Brazil, this recognition simplifies compliance by preventing duplication of top-up tax calculations and payments under alternative methodologies. As Brazil now holds QDMTT safe harbour status, companies must now ensure their Pillar Two computations align with Brazil’s framework and the additional CSLL mechanics.
Brazil’s implementation of the QDMTT ensures proper taxation of profits within its borders, discouraging profit shifting to low-tax regions. This aligns with global corporate tax standardisation efforts and promotes fair competition for businesses locally and globally.
