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Brazil Publishes Law for Top-up Tax through Additional Social Contribution on Net Profit and Plans to Introduce Income Inclusion Rule and New CFC Regime

02 January 2025

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Approved Changes

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Brazil

Brazil published Law No. 15.079 of 27 December 2024 in the Official Gazette on 30 December 2024. The law, which is generally effective from 1 January 2025, provides for the introduction of the Additional Social Contribution on Net Profit (CSLL) in line with Provisional Measure No. 1.262 of 3 October 2024. The Additional CSLL 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...