The measure was adopted to follow OECD standards and will be regulated by federal revenues; for foreign multinationals with an annual turnover exceeding 750 million euros, an additional charge applies
BRASILIA-IL government published this Thursday 3 in an extraordinary edition of the Official Journal (DOU), a provisional measure establishing a further Social contribution on net profit (CSLL) for the adaptation of Brazilian legislation to the Global Rules Against Tax Base Erosion – GloBE Rules. The additional tariff applies to foreign multinationals, with annual revenues exceeding 750 million euros. Follows pillar 2 of Organization for Economic Co-operation and Development (OECD)which establishes a minimum tax rate of 15% for these large companies globally. The government did not disclose the expected revenue from the measure.
The effective minimum taxation established by the MP will be through an additional CSLL. The special secretary of the Revenue Agency, Robinson Barreirinhas, the undersecretary for Taxation and Litigation of the Revenue Agency, Cláudia Pimentel, and the director of the Program of the Extraordinary Secretariat for Tax Reform, Daniel Loria, will illustrate the measure on Friday in a press conference, 4, in Sao Paulo.
THE Federal revenue it is what will regulate this tariff, including currency conversion, adjustments to be made and the entire regulatory framework. These rules will be periodically updated to be in line with the reference documents approved by the OECD, in order to satisfy the requirements to qualify the Additional CSLL as Qualified Domestic Minimum Top-up Tax (QDMTT).
The MP already contains definitions of the constituent entities of multinational corporate groups and the GloBE profit or loss concepts for each of them. Also listed are the covered taxes adjusted by these companies and those that will not be taken into account in this calculation. The text also explains the logic behind the formation of the effective tax rate and the transition rules.
This is the second major MP the government has published in the late-night DOU Extra this week. A provision was issued on Wednesday that extends the deadline within which financial institutions can deduct losses resulting from default from the calculation basis of the IRPJ and CSLL. This measure is expected to generate additional revenues that will exceed R$16 billion in 2025.
Source: Terra
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