Brazil: Tributação Mínima Global 15%: Brasil Atualiza Regras OCDE para Multinacionais

In October 2025, the Brazilian Federal Revenue Service updated the regulation that introduced a minimum taxation of 15% applicable to multinational companies in Brazil. This measure incorporates the new international guidelines from the OECD published in June 2024 and reinforces Brazil’s commitment to the Global Anti-Base Erosion Rules (GloBE Rules).

What is Global Minimum Taxation?

Global minimum taxation is an initiative by the OECD (Organization for Economic Cooperation and Development) known as Pillar Two, which sets a minimum rate of 15% for multinational companies with global revenue exceeding €750 million.

Objective: Prevent large multinational groups from shifting profits to countries with very low taxation (tax havens).

How Does It Work in Brazil?

In Brazil, the minimum taxation was implemented through an Additional CSLL, established by Law No. 15,079/2024.

Technical name: Qualified Domestic Minimum Top-up Tax (QDMTT)

Advantage for Brazil: Allows the country to exercise priority in taxing multinational groups subject to low tax burdens, rather than allowing other countries to levy this tax.

October 2025 Update

The Normative Instruction RFB No. 2,282/2025, published on October 3, 2025, introduced important updates:

Main Changes

• Adjustments in tracking and recapturing tax liabilities
• Rules for discrepancies between accounting and tax values of assets and liabilities
• Definitions on the allocation of taxes among entities in different jurisdictions
• Criteria for classifying transparent and hybrid entities
• Specific rules for securitization vehicles
• Correction of duplication in the application of Withholding Tax on Interest on Equity (JCP)

Who is Affected?

Subject Companies

Multinational groups with:

• Annual global revenue above €750 million
• Operations in multiple countries
• Effective tax burden below 15% in any jurisdiction

Practical Example

Situation: Multinational with operations in Brazil

Explanation: If the company pays only 10% in taxes, Brazil charges an additional 5% to reach the minimum of 15%.

Effective Dates

OECD GloBE Rules

The Global Anti-Base Erosion Rules (GloBE) are part of the international agreement known as the Two-Pillar Solution:

Pillar One

Redistribution of taxing rights over profits of large digital multinationals.

Pillar Two (Minimum Taxation)

Establishes a global minimum rate of 15% to prevent base erosion.

Impacts for Companies

Affected Multinationals

• Need to review global tax structure
• End of aggressive planning with tax havens
• Increase in effective tax burden
• Greater complexity in tax calculation

Brazilian Companies

• Higher revenue for Brazil (instead of other countries)
• More balanced competitiveness
• Legal certainty with clear rules

International Comparison

Frequently Asked Questions

1. Do all companies pay 15%?

No. Only multinational groups with global revenue above €750 million.

2. How is the effective rate calculated?

The total taxes paid are divided by the adjusted accounting profit in each jurisdiction.

3. What happens if the company already pays more than 15%?

Nothing. The additional only applies if the effective burden is below 15%.

4. Do tax havens still work?

Partially. The benefit is reduced, as the home country (like Brazil) will charge the difference up to 15%.

5. When does it take effect in Brazil?

Interpretative updates are already in effect. Other rules from January 1, 2026.

Also read: 2025 Tax Reform: Complete Guide CBS and IBS – Timeline and Impacts

Also read: 2026 Tax Planning: How to Legally Reduce Taxes

Related Articles

See also: 2025 Tax Reform | Tax Planning

Official Sources

• Brazilian Federal Revenue Service – Official News (Oct/2025)
• IN RFB No. 2,282/2025
• Law No. 15,079/2024
• OECD – Pillar Two

Last updated: October 22, 2025 | Information verified from official sources of the Brazilian Federal Revenue Service and OECD

Does your multinational company need to comply? Consult our team specialized in international taxation.