The Brazilian tax scenario underwent a significant transformation with the publication of Provisional Measure No. 1,262/2024 and RFB Normative Instruction No. 2,228/2024. These new rules incorporate the OECD’s GloBE rules, establishing an additional to the CSLL and aiming to guarantee an effective global minimum tax on company profits.
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.
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