On 1 October 2026, the Brazilian Federal Revenue Service amended Normative Instruction RFB 2.228/2024, which regulates the Additional CSLL (Pillar Two implementation). The amendment introduces the Globe Simplified Rule for Substance-based Income Exclusion (Regra Simplificadora Globe para Incentivo Fiscal baseado na Substância) and extends the applicability period of the Globe Transition Simplified Rule (Regra Simplificadora Globe de Transição). These changes aim to reduce compliance burden for multinational enterprises by providing safe harbors and simplified calculations aligned with the OECD GloBE framework. The updates are effective immediately and apply to fiscal years beginning on or after 1 January 2024.
Key Takeaways
- Substance-based Exclusion Simplified: MNEs can now use a streamlined method to compute the Substance-based Income Exclusion (SBIE), reducing data requirements.
- Extended Transition Relief: The transition safe harbor is available for additional fiscal years, easing the initial compliance phase.
- Immediate Application: Taxpayers should review their Pillar Two models and adjust calculations for the current reporting cycle.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement