Instituted Additional CSLL on Multinational Profits

Law seeks to align Brazil with international rules against tax base erosion

The Brazilian tax framework has recently undergone a significant update with the sanction of Law 15.079/2024 by the Federal Government. This new legislation introduces the Additional Social Contribution on Net Profit (CSLL) as part of Brazil's alignment with the Global Anti-Base Erosion (GloBE) Rules, an initiative led by the OECD and the G20.

Objective of the new law

The introduction of the additional contribution aims to align Brazil with international guidelines for an effective minimum taxation rate of 15%. This measure is part of a global effort to prevent tax base erosion and ensure a fair distribution of tax revenues among countries.

Who Is Subject to the Additional Contribution? 

The new regulation will apply exclusively to multinational groups meeting the following requirement: having annual revenues equal to or exceeding 750 million euros in the Consolidated Financial Statements of the Ultimate Parent Entity in at least two of the last four fiscal years reviewed.

According to federal government data, it is estimated that this 15% rate will affect 290 multinationals operating in Brazil. The collection will begin in the fiscal year 2025, with payment due by the last day of the seventh month following the end of the fiscal year. However, the exact date may vary, as a fiscal year does not necessarily align with the calendar year for all companies and multinationals.

The Special Secretariat of the Federal Revenue Service will be responsible for the technical regulation of this additional contribution, including currency conversions and accounting definitions.

Tax Support

DPC stays up-to-date with developments in Brazilian legislation to provide clients with guidance aligned with best fiscal practices. Count on our team's support: dpc@dpc.com.br.