The proposal aims to update the regulations to incorporate the latest OECD guidelines under the GloBE Rules (Pillar 2), ensuring that the Adicional de CSLL remains classified as a Qualified Domestic Minimum Top-up Tax (QDMTT).

The main changes involve the incorporation of guidelines published in January 2026 regarding the Side-By-Side Package, notably the GloBE Simplifying Rule for Substance-Based Tax Incentives (RSGIF), as well as conceptual and operational adjustments to provide greater clarity in the application of the rules.

As a basis for contributions, a file containing the proposed text to be implemented has been made available, covering the following points:

• General provisions;
• Qualified Tax Incentive, with general definitions;
• Tax incentives based on expenditure and production;
• Expenditure incurred and quantities produced;
• Qualified Refundable Tax Credit;
• Qualified Tax Incentive used in the Tax Year; and
• Substance Threshold.

Comments must be submitted by 3 May via email to the address provided by the RFB, indicating whether you agree or suggesting amendments, as well as any additional points that require regulation.

Moreover, it should be noted that Brazil recently applied to the OECD to be a Qualified Side-by-Side Regime alongside with the USA. Upon the OECD acceptance, the Qualified Side-by-Side status would not change the mechanics of Adicional de CSLL, but it could secure groups subject to the Adicional de CSLL exemption from the other two “backstop” taxes within the Pillar 2 system called the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR).

Our team is continuing to monitor this matter and is available to provide further clarification.

O post Tax Authorities launch consultation on regulations for the Brazilian QDMTT apareceu primeiro em Lavez Coutinho.

In an interview with Valor Econômico, our partner Rinaldo Braga analysed the impact of the new guidance, which redefines the criteria under which such bonuses are not characterised as salary, thereby preventing the levy of social security contributions.

The matter has significant practical implications, as bonus schemes are strategic tools for workforce management, productivity and talent retention, and any potential reclassification may result in substantial financial exposure.

Click here to read the full article in Valor Econômico.

O post Taxation of Employee Bonuses in Brazil Gains New Relevance After COSIT Ruling No. 10 apareceu primeiro em Lavez Coutinho.

The new Protocol represents an important step toward the modernization of Brazil’s international tax policy, promoting greater legal certainty and alignment with OECD best practices.

The amendments directly affect the taxation rules on:

• Dividends

• Interest

• Royalties

• Technical services

In addition, the Protocol introduces Limitation on Benefits (LoB) provisions, designed to prevent treaty abuse and ensure that benefits are granted only to taxpayers meeting the required economic substance and effective tax residence criteria.

These changes aim to strengthen tax transparency and prevent tax avoidance and evasion practices, bringing Brazil closer to international standards of tax cooperation.

Our team has reviewed the Decree in full and prepared an exclusive One Page summarizing the main changes and new rates applicable under the Brazil–India Double Taxation Agreement.

Click here to access the full material.

O post The Brazilian Government Promulgates Protocol Amending India-Brazil Double Taxation Agreement apareceu primeiro em Lavez Coutinho.

In an article published in the international edition of International Tax Review (ITR), our partners Raphael Lavez and Rômulo Coutinho analyze the strategic impacts of the new tax framework, addressing key topics such as the coexistence of regimes, the new credit system, and destination-based taxation.

More than just a legislative change, the reform represents a transformation that requires the direct involvement of CEOs and Boards of Directors.

In this context, it is essential for business leaders to anticipate the challenges and start making strategic decisions now, ensuring readiness for the new system and mitigating risks that could affect competitiveness and compliance.

Read the full article to understand why the Tax Reform must take a central place on the leadership agenda (subscribers only): (acesso exclusivo para assinantes): Clique aqui!

O post Raphael Lavez and Rômulo Coutinho discuss practical challenges of Tax Reform for businesses apareceu primeiro em Lavez Coutinho.

What do GloBE and the Additional CSLL mean?

GloBE (Global Minimum Tax) is an international mechanism that seeks to prevent multinational companies from transferring their profits to countries with lower taxation. The Additional CSLL, in turn, is a complementary tax on companies’ net profits, calculated on the basis of the global minimum profit required by the GloBE rules.

What are the main impacts for companies?

The new rules bring various challenges and opportunities for Brazilian companies, especially multinationals. Among the main impacts are the need for accounting adjustments and tax planning opportunities.

How can companies prepare?

To adapt to the new scenario, companies should carry out a detailed analysis of the impact of the new rules, considering their operations, corporate structure and the jurisdictions involved; adapt their accounting and tax systems to calculate the additional CSLL and generate the information needed to meet the new requirements, and seek specialized advice to help implement the necessary measures.

Conclusion

The new GloBE rules and the Additional CSLL  represent a significant change in the Brazilian tax landscape. Companies that adequately prepare for these changes will be better positioned to face the challenges and seize the opportunities of the new scenario.

Download our guide by clicking here and find out how to adapt to the new rules!

O post GloBE and Additional CSLL impact multinational companies in Brazil apareceu primeiro em Lavez Coutinho.

Based on international and Brazilian experiences, we will debate the challenges and solutions from a practical experience standpoint to face this new scenario regarding transfer pricing.

Registration at link: Registration Form

O post Transfer Pricing New Legislation apareceu primeiro em Lavez Coutinho.