Map the evidence before making the election.
- Brazil opens an optional one-year GloBE safe harbour. Receita Federal announced Normative Instruction RFB No. 2,342/2026 on 1 October. Brazilian entities in multinational groups meeting the EUR 750 million threshold in at least two of the four preceding fiscal years may elect the transitional route for one fiscal year beginning on or after 1 January 2026. The election is not automatic. Confirm scope entity by entity, map qualifying financial statements and preserve reconciliation evidence before choosing the simplified route. Tax teams should document why each Brazilian entity qualifies, because the safe harbour simplifies the computation but does not remove the need for a defensible election file.
- PGFN opens a new FGTS settlement window. Notice PGDAU No. 12/2026 covers eligible FGTS debts enrolled in active debt up to R$45 million. Applications run from 15 October 2026 until 29 January 2027 at 19:00 Brasília time. Discounts do not reduce amounts legally owed to workers, and debtors on the forced-labour register are excluded. Reconcile payroll, worker-linked balances and active-debt records and compare the total economics before migrating an agreement. Treasury should also confirm that the negotiated structure does not obscure amounts that must remain available to workers.
- Domestic-violence leave now has a clearer payment route. INSS guidance published on 1 October states that a judicially ordered protective leave may last up to six months. The employer bears the first 15 days and INSS pays from day 16, without a qualifying-period requirement. Handle the case confidentially and establish a restricted workflow for the court order, employer-paid days, benefit referral and return-to-work controls. Access should be limited to staff who need the information for payment or benefit processing, with ordinary managers receiving only the operational information required.
- Split-payment testing enters a new phase. Receita’s restricted production testing starts on 15 October, without real customer transactions, tax collection or penalties. Other payment service providers may enrol from 16 November. This is preparation, not a general effective obligation. Map ERP, payment and invoice data, identify reconciliation gaps and assign owners before broader rollout. The practical objective is to test data integrity and exception handling while the environment carries no production tax effect.
Primary sources: Receita Federal — GloBE safe harbour; PGFN — FGTS settlement; INSS — protected leave; Receita Federal — split-payment testing.