The surcharge applies to foreign multinationals with an annual turnover exceeding 750 million euros; The expectation is to raise around R$8 billion per year after 2029
THE Senate approved this Wednesday, 18th, the bill 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. Signed by the head of government in the Chamber, MP José Guimarães (PT-CE), the text was approved by deputies on Tuesday 17th and will now move on to presidential approval.
The proposal became the subject of a temporary measure issued in early October by the Department governmentat the suggestion of the economic team. It was decided, in turn, that the matter would be addressed by invoice.
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 an effective minimum tax rate – i.e. an average that takes into account all the taxes that companies already pay – for these large companies globally.
The measure is part of Finance Minister Fernando Haddad’s strategy to fight so-called fiscal erosion and increase revenue. According to government estimates, the proposal will however have no impact on the 2025 budget. The expectation is to raise around R$8 billion per year when there is “stability”, which is expected after 2029. However, from 2026 onwards Then. , it will be possible to start verifying the impact on the budget.
The Federal Revenue Service will regulate this charge, 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 project already contains definitions of the constituent entities of groups of multinational companies 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.
Congress also took advantage of the proposal to extend universal base (TBU) tax mechanisms through 2029. The TBU concerns tax rules that affect the profits of Brazilian multinationals abroad. Today they are only valid until the end of this year, and the prospect of the year ending without the Legislature extending these rules worries the private sector.
“Our country needs to adapt to the global scenario. If Brazil does not adopt the CSLL surtax, the undertaxed corporate income – i.e. with an effective rate lower than 15% – generated in Brazil will be collected by another jurisdiction where the operate a group of multinationals that have already introduced the GloBE Rules into their legislation. Around 36 countries already have rules in force in 2024 and more than 20 will implement them from 2025”, he warned. in a statement. in plenary the rapporteur on the issue in the Senate, Alan Rick (União-AC).
According to him, the proposal also highlights the urgency of a comprehensive reform of the TBU regime. It therefore provides for the obligation for the Executive to present, in 2025, a new proposal for the regulation of CFCs (Controlled Foreign Corporations), based on international guidelines and best practices. “This commitment reflects the need to modernize the tax system, promoting greater fairness and competitiveness on the global stage,” he said.
Source: Terra
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