Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 11 OCTOBER 2024

Brazil Publishes Provisional Measure Introducing Additional CSLL To Adapt To OECD GloBE Rules

Mayer Brown
Mayer Brown
Contributor
Mayer Brown

Mayer Brown

Mayer Brown is a leading international law firm positioned to represent the world’s major...

View firm profile
Explore more from Mayer Brown

On October 3, 2024, Provisional Measure (PM) No. 1,262/2024 was enacted, introducing an addition to the Social Contribution on Net Income (the "Additional CSLL")...

BrazilTax
Guido Vinci
Guido Vinci
Flávia Cavalcanti
Flávia Cavalcanti
Niandra Soares
Niandra Soares
Karolina Rosen
Karolina Rosen
Author LinkedIn connections

On October 3, 2024, Provisional Measure (PM) No. 1,262/2024 was enacted, introducing an addition to the Social Contribution on Net Income (the "Additional CSLL"), in order to adapt to the Organisation for Economic Co-operation and Development's Global Anti-Base Erosion (GloBE) Rules under Pillar 2. These rules aim to elevate the effective tax rate on corporate income of large Multinational Enterprise (MNE) Groups to a minimum of 15% in each jurisdiction.

According to the federal government's announcement, PM No. 1,262/2024 is structured to ensure that the Additional CSLL qualifies as a Qualified Domestic Minimum Top-Up Tax (QDMTT).

On the same date, the Brazilian Federal Revenue Office (RFB) published Normative Instruction (NI) No. 2,228/2024, which regulates the Additional CSLL, and which is currently open to public consultation until November 10, 2024.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Visit us at mayerbrown.com

Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.

© Copyright 2026. The Mayer Brown Practices. All rights reserved.

This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Complementary Law No. 236/2026: Amendments To The Brazilian Tax Code And Advances In The Resolution Of Tax And Customs Disputes

Brazil's Supplementary Law No. 236/2026 introduces sweeping reforms to the Brazilian Tax Code, establishing new caps on tax penalties, expanding taxpayer safeguards during audits and collection proceedings, and incorporating alternative dispute resolution mechanisms including arbitration and mediation. The legislation mandates state and local governments to align their tax procedures with these new national standards within two years or face automatic application of federal provisions.
BrazilTax
Mayer Brown
Mayer Brown
Article

Lei Complementar 236/2026 altera penalidades e prazos no CTN

A Lei Complementar nº 236/2026 introduz mudanças significativas no Código Tributário Nacional, estabelecendo novos limites para multas tributárias, ampliando garantias dos contribuintes e uniformizando procedimentos administrativos fiscais em todo o Brasil. As alterações incluem vinculação da administração a decisões judiciais, redução de penalidades em diversas situações e padronização de prazos processuais.
BrazilTax
KLA Advogados
KLA Advogados
Article

GECEX Resolution No. 957/2026: Extension Of The 12% Export Tax Rate On Crude Petroleum Oils And Bituminous Minerals

Brazil's Executive Management Committee of the Foreign Trade Chamber has extended the 12% export tax rate on crude petroleum oils and bituminous mineral oils for an additional 60 days. The extension, formalized through GECEX Resolution No. 957/2026, maintains the tax structure previously established under Resolution No. 938/2026 and takes effect on September 8, 2026.
BrazilTax
Mayer Brown
Mayer Brown
Article

Brazilian Federal Revenue Service Publishes New Rules On Monitoring Of Tax Benefit Eligibility By Legal Entities

Brazil's Federal Revenue Service has introduced new monitoring procedures that will require legal entities to meet specific compliance criteria to maintain their tax benefits and incentives. Companies must satisfy requirements including federal tax regularity, absence of administrative sanctions, and proper registration, with automated periodic verification beginning September 1, 2026, and a 20-business-day correction window for identified irregularities.
BrazilTax
Mayer Brown
Mayer Brown
Article

Alerta de Julgamento: STF julgará a tributação, pelo PIS/COFINS, dos créditos presumidos de ICMS

O Supremo Tribunal Federal julgará em setembro de 2026 se empresas podem excluir créditos presumidos de ICMS da base de cálculo do PIS/COFINS. A decisão terá efeitos vinculantes para todos os casos sobre o tema e pode impactar significativamente empresas que aproveitam esse benefício fiscal. Contribuintes argumentam que tais créditos constituem patrimônio dos Estados para fomento empresarial e não devem ser tributados como receita.
BrazilTax
KLA Advogados
KLA Advogados
Article

IRRF sobre lucros e dividendos tem novas regras de recolhimento

A Receita Federal estabeleceu procedimentos distintos para retenção e recolhimento de 10% de IRRF sobre lucros e dividendos distribuídos por pessoas jurídicas brasileiras, diferenciando tratamento entre não residentes e pessoas físicas residentes com pagamentos superiores a R$50 mil mensais. A orientação detalha códigos de receita, prazos de vencimento e procedimentos específicos para cada categoria de beneficiário.
BrazilTax
KLA Advogados
KLA Advogados
Video

The Impact Of Tax Reform On The Manaus Free Trade Zone: Constitutional Amendment No. 132/2023 And Supplementary Law No. 214/2025 (Video)

Brazil's Tax Reform introduces a complex framework of IBS and CBS regulations specifically designed to preserve the Manaus Free Trade Zone's competitive advantage through strategic IPI maintenance, zero-rating mechanisms, and deemed tax credit systems. Companies operating in the Manaus Industrial Pole must navigate new rules governing product classifications, import suspensions converted to exemptions, and intricate credit appropriation requirements that fundamentally reshape regional tax incentives.
BrazilTax
Mayer Brown
Mayer Brown
Article

Trump Administration Announces New Enforcement Actions Against Employers In H-1B And PERM Fraud Probes

The Trump Administration has launched an unprecedented investigation into H-1B visa and PERM labor certification programs, with the Department of Labor's Office of Inspector General issuing dozens of subpoenas and suspending employers' ability to process applications. Federal agencies are deploying new enforcement tools including whistleblower programs and criminal prosecution threats...
United StatesImmigration
Mayer Brown
Mayer Brown
Article

AI Regulation In Singapore And Hong Kong: A Mid-Year Checkpoint

Singapore and Hong Kong continue to regulate artificial intelligence through existing laws and voluntary frameworks rather than comprehensive AI statutes, but the first half of 2026 has brought sharper emphasis on practical controls including agentic AI governance, assurance and testing, financial-sector oversight and cyber resilience. Both jurisdictions are building concrete expectations around risk management, transparency, human accountability and operational safeguards while avoiding horizontal AI legis
GlobalStrategy
Mayer Brown
Mayer Brown
Article

DOL Announces New Enforcement Policy For Mental Health Parity Nonquantitative Treatment Limitation Requirements

The US Department of Labor has issued new guidance establishing a streamlined framework for enforcing mental health parity requirements under MHPAEA, focusing enforcement on three priority areas while maintaining nonenforcement of controversial 2024 rule provisions. This guidance aims to reduce compliance burdens on plan sponsors while ensuring participants maintain access to mental health and substance use disorder benefits comparable to medical and surgical coverage.
United StatesEmployment and HR
Mayer Brown
Mayer Brown
Article

European Union Adopts 21st Package Against Russia & Parallel Sanctions On Belarus

The European Union has adopted its 21st package of sanctions against Russia and Belarus, significantly expanding restrictions across finance, energy, crypto, and military-industrial sectors. This comprehensive package introduces 218 new designations, freezes the oil price cap, imposes stricter LNG controls, and closes loopholes while reinforcing measures to discourage third-party sanctions evasion. The sanctions also strengthen protections for EU operators and facilitate business exits from Russia.
European UnionInternational Law
Mayer Brown
Mayer Brown
Article

Russia/Ukraine Sanctions Update - Month Of August 2026

This monthly update tracks the latest developments in Russia/Ukraine sanctions across US, EU, and UK jurisdictions, covering new designations, general license extensions, legislative proposals, and enforcement actions. The update also examines Russia's countermeasures, including shadow fleet expansion and legal restrictions on foreign investors, while highlighting international coordination efforts by Switzerland, Canada, and New Zealand.
GlobalInternational Law
Mayer Brown
Mayer Brown
Article

SEC Staff Statement On Fair Value Measurement And Disclosure Considerations For Private Assets

The SEC Staff has issued new guidance addressing fair value measurement and disclosure practices for private credit and other illiquid assets held by registered funds and business development companies. As private credit portfolios have grown nearly 60% since 2020, reaching $270 billion, regulators emphasize the critical importance of robust valuation methodologies, transparent disclosure of significant judgments, and careful application of accounting standards when market prices are unavailable.
United StatesAccounting and Audit
Mayer Brown
Mayer Brown
Article

Trump’s China Visit Will Likely Extend Trade Truce, While Points Of Friction Remain

President Trump's May 2026 state visit to China yielded agreements on trade boards, agricultural purchases, and tariff stability, but tensions persist over export controls and military company designations. As both nations pursue "strategic stability," multinational companies face increasing compliance conflicts from competing regulatory frameworks. Will the planned bilateral forums successfully navigate friction points in semiconductors, rare earths, and defense sectors?
ChinaInternational Law
Mayer Brown
Mayer Brown
Article

EU AI Act News: Digital Omnibus On AI, New Guidance On Risk Classification, GPAI, And Transparency Obligations

The European Union's Artificial Intelligence Act continues to evolve with significant regulatory updates that reshape compliance timelines and clarify key obligations. Recent developments include the Digital Omnibus on AI, which extends implementation deadlines for high-risk systems and introduces new prohibitions on harmful AI applications, alongside comprehensive guidance from the European Commission on classification criteria, transparency requirements, and general-purpose AI model obligations.
European UnionIntellectual Property
Mayer Brown
Mayer Brown