🇧🇷 Tax27 Dec 2024
Brazil brings in a 15% minimum tax for large multinationals
Brazil's Law no. 15,079 of 27 December 2024 creates an additional social contribution on net profit (CSLL) so that multinational groups with consolidated revenue of at least EUR 750 million pay an effective 15% minimum tax on Brazilian profits, from 1 January 2025. It works as a qualified domestic minimum top-up tax under the OECD rules. Brazil has not adopted the income inclusion or undertaxed profits rules.
Law no. 15,079 of 27 December 2024 adapts Brazilian law to the OECD's global minimum tax (Pillar Two) rules.
What changed
- An additional CSLL tops up tax on Brazilian profits to an effective 15%.
- It applies to multinational groups whose ultimate parent reported consolidated revenue of at least EUR 750 million in at least two of the four previous years.
- It applies from 1 January 2025, under rules set by the Receita Federal.
- Brazil adopted only the domestic top-up tax, not the income inclusion rule or the undertaxed profits rule.
- In August 2025 the OECD/G20 Inclusive Framework recognised the additional CSLL as a qualified domestic minimum top-up tax.
Who is affected
Brazilian entities of large multinational groups and their tax and finance teams.