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Brazil Introduces Additional Social Contribution on Net Profit as Top-up Tax for Pillar 2

07 October 2024

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Approved Changes

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Brazil

Brazil has published Provisional Measure No. 1.262 of 3 October 2024 and Normative Instruction No. 2.228 of 3 October 2024 for the introduction of an Additional Social Contribution on Net Profit (CSLL) that is meant to meet the requirements of a qualified domestic minimum top-up tax (QDMTT) in line with the Pillar 2 global minimum tax rules. The Additional CSLL percentage is equal to 15% minus the effective tax rate of the constituent entities in Brazil of an in-scope MNE group, which includes MNE groups with annual consolidated revenue of at least EUR 750 million in at least two of...