The regulation clarifies the operational elements of tax obligations related to the calculation and payment of the additional CSLL, applicable to multinational companies.
By Rafael Maniero
Legale Overseas, no. 976.
The Brazilian Federal Revenue Service (RFB) issued, last week, a regulation governing obligations related to the global minimum tax in the country, applicable to multinational groups. The measure details operational aspects concerning the calculation and payment of the additional Contribution on Net Profits (CSLL), in line with the minimum taxation regime adopted by Brazil.
The regulation establishes that the additional CSLL must be reported in the Declaration of Federal Tax Debts and Credits (DCTFWeb) by the sixth month following the end of the fiscal year, with payment due by the last business day of the seventh month following the close of the fiscal year.
Brazil has adopted the Qualified Domestic Minimum Top-up Tax (QDMTT), which provides for a minimum taxation of 15% on income attributable to the Brazilian jurisdiction and requires specific adjustments. The measure aligns with the practices recommended by the Organisation for Economic Co-operation and Development (OECD) to prevent tax base erosion (GloBE Rules – Global Anti-Base Erosion) and to combat tax avoidance.
Considering that 2026 will be the first year of compliance with these obligations, relating to fiscal year 2025, it becomes essential that companies subject to the global minimum tax—namely, multinational groups with annual global revenues exceeding €750 million in at least two of the last four years—take the necessary steps to comply with the new requirements.
Vaz de Almeida Advogados continuously monitors regulatory developments related to the global minimum tax, supporting clients and partners in understanding the matter.
Translation Disclaimer
This document was originally drafted in Portuguese and subsequently translated into English using artificial intelligence (AI).
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