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Brazilian Congress approves Bill of Law introducing OECD Pillar Two rules

20 December 2024

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Tax Alerts, Information Reporting, Legis...

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Brazil

Congress has approved legislation implementing the Pillar Two rules for Brazil.The Bill of Law largely replicates the Provisional Measure published by the Executive Branch in October 2024. On 18 December 2024, the Brazilian Congress approved Bill of Law 3,817, which implements Pillar Two rules in the country. The Bill of Law introduces a Qualified Domestic Minimum Top-up Tax (QDMTT) but does not include the Income Inclusion Rules (IIR) or the Undertaxed Payments Rule (UTPR). The Brazilian QDMTT rules are largely aligned with the Global anti-Base Erosion (GloBE) Model Rules and are scheduled to take effect for fiscal years starting on or...