Global minimum tax 15%: preparing for Pillar Two

Executive summary: Groups with global revenue above €750 million must comply with OECD Pillar Two. Brazil is moving ahead with regulations (IN RFB 2.161/2024 and Bill 2330/2025). A structured timeline plus jurisdiction-level Effective Tax Rate (ETR) calculations will secure compliance, prevent double taxation, and align the Brazilian reform with the global agenda.

📋 Índice

• → Global minimum tax overview
• → Who is in scope
• → Calculating the ETR per jurisdiction
• → Integrating with CBS/IBS and the Brazilian reform
• → Compliance and governance checklist
• → Recommended 2024-2026 timeline
• → Frequently asked questions
• → Next steps
• → Legal and technical references

Market benchmark: EY, PwC, and OECD reports explain Pillar Two but rarely tailor spreadsheets or schedules to Brazilian rules. This guide integrates global requirements with local milestones (IN 2.161/2024, PL 2330/2025) and includes exclusive tools.

Global minimum tax overview

Pillar Two (GloBE) sets a 15% minimum effective tax rate for multinationals. It relies on three mechanisms:

• Income Inclusion Rule (IIR): the parent entity collects the top-up tax when subsidiaries pay less than 15%.
• Undertaxed Payments Rule (UTPR): allows other jurisdictions to deny deductions or impose additional tax when no IIR is applied.
• Qualified Domestic Minimum Top-up Tax (QDMTT): domestic tax ensuring local collection before foreign jurisdictions claim the top-up.

Who is in scope

• Multinationals with global revenue ≥ €750M in the previous two fiscal years.
• Brazilian companies with foreign subsidiaries (CFC) and foreign groups operating in Brazil.
• Startups/scale-ups that are part of global groups must submit local data.

Attention: Brazilian incentives (Sudene, ZFM, Lei do Bem) affect the ETR. Analyze whether a domestic QDMTT will be required to retain revenue in Brazil.

Competitive comparison: International materials seldom cover how Brazilian incentives alter the ETR. We detail how to map each benefit and simulate the local top-up tax.

Calculating the ETR per jurisdiction

1. Gather accounting data — profit before tax, GloBE adjustments (excluded items, timing differences).
2. Compute covered taxes — taxes paid or due in each country.
3. Determine GloBE Income — adjusted base for Pillar Two.
4. ETR = Covered taxes / GloBE Income — benchmark against 15%.
5. Top-up Tax = (15% – ETR) × GloBE Income (subject to relief rules).

Tool: “Jurisdictional ETR Calculator” spreadsheet with tabs for data input, adjustments, and consolidation.

Differential: We include dedicated fields for Brazilian incentives (Sudene, ZFM, Lei do Bem) and a QDMTT simulator—absent from generic templates.

Integrating with CBS/IBS and the Brazilian reform

• Brazilian incentives (presumptive credits, regional programs) may reduce the tax base—confirm whether they qualify as Qualified Refundable Tax Credits (QRTCs).
• Quantify CBS/IBS impacts: financial credits can affect the effective tax burden.
• Align transfer-pricing policies and intangible treatment with Pillar Two.

Compliance and governance checklist

• Inventory all group entities and jurisdictions.
• Data governance: integrated ERP, consolidation, and BI systems.
• Updated transfer-pricing policy aligned with OECD rules.
• Global tax committee with meeting calendar and minutes.
• Internal and external audit procedures tailored to GloBE data.

Recommended 2024-2026 timeline

CTA: Download the GloBE Timeline 2024-2026 with tasks, owners, and deliverables.

Benchmark: The GloBE Implementation Handbook 2024 indicates companies starting diagnostics 18 months early reduce remediation by up to 30%. Use this KPI for global/local committees.

Frequently asked questions

• Does my company fall under GloBE? If global revenue ≥ €750M, yes—confirm with headquarters.
• Do Brazilian incentives count as covered taxes? Only if classified as QRTCs; review each case.
• How do we handle data from non-IFRS countries? GloBE adjustments convert local GAAP figures; prepare reconciliations.
• Should we revisit transfer pricing? Yes, to avoid misalignments that depress ETR.
• What penalties apply? Fines and adjustments follow if reports contain discrepancies.

Next steps

1. Confirm scope and coordinate with HQ.
2. Start gathering tax/accounting data with GloBE adjustments.
3. Review Brazilian incentives and international contracts.
4. Build the 2024-2026 roadmap with global/local committees.
5. Prepare documentation for audits and official filings.

Related articles:
– International expansion in five steps
– Transfer pricing 2025
– Tax contingency management

Legal and technical references

• OECD Pillar Two / GloBE framework.
• Normative Instruction RFB 2.161/2024 (CbCR).
• GloBE Implementation Handbook 2024.
• Brazilian Bill 2330/2025 (QDMTT).
• COSIT Normative Opinion 01/2025.
• Receita Federal Technical Note 14/2025 (safe harbours).

Need global tax support? FDS Tributário bridges Brazilian and international policies, computes ETR, revises contracts, and synchronizes deliverables with headquarters to keep your group compliant worldwide.