On December 27, Law No. 15,079/2024 was enacted, introducing an effective minimum tax rate of 15% on the profits of multinational groups operating in Brazil. This measure aligns Brazil with the global agreement to prevent tax base erosion, known as the GloBE Rules (Global Anti-Base Erosion).
Who Will Be Affected?
The new regulation targets multinationals with consolidated annual revenues exceeding 750 million euros (approximately R$ 4.78 billion), based on results from at least two of the past four fiscal years. It is estimated that around 290 multinational corporations will be affected, including 20 Brazilian companies with global operations.
How Will the Tax Be Applied?
- An additional tax on the Social Contribution on Net Profit (CSLL) will be introduced.
- This additional tax will be applied complementarily, ensuring that profits generated in Brazil are not subject to an effective tax rate below 15%.
- The tax will take effect starting in the 2025 fiscal year, with payment due by the last day of the seventh month following the close of each group’s fiscal year.
Objectives and Impact
The measure aims to:
- Establish a minimum threshold for international taxation, reducing competition between tax jurisdictions.
- Prevent “tax revenue exportation”: if one country fails to tax adequately, another country with the GloBE Rules in place can collect the supplementary tax.
- Increase tax revenue: the Ministry of Finance projects gains of R$ 3.44 billion in 2026, R$ 7.28 billion in 2027, and R$ 7.69 billion in 2028.
Global Context
Currently, 37 countries have already implemented the GloBE Rules. By adopting this model, Brazil aligns itself with international standards and addresses the challenges of the digitalized economy, adjusting its legislation to prevent revenue losses and maintain tax competitiveness.
Recommendations for Taxpayers
Multinational companies should:
- Review their global tax operations to assess the impact of the minimum tax.
- Properly plan cash flows, considering the deadline for paying the additional CSLL.
- Monitor future regulations that may provide details on administrative procedures and methods for calculating the tax.