The Provisional Measure aims to follow the GloBE Model Rules and introduces a QDMTT.The QDMTT rules are expected to apply starting on January 2025, with a transitional safe harbor period of three years.Taxpayers should evaluate the implications of the Provisional Measure and prepare to comply with potential filing requirements in case they do not qualify for safe harbors. On 3 October 2024, the Brazilian Government published Provisional Measure (PM) No. 1.262 and Normative Instruction (NI) No. 2.228 to introduce the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Pillar Two rules in Brazil. The PM aims...