Tax & Accounting · 1 October 2026
Receita Federal announced Normative Instruction RFB No. 2,342/2026, which amends Brazil’s Additional CSLL rules under the GloBE minimum-tax framework. The measure applies to constituent entities of multinational groups within the EUR 750 million consolidated revenue scope.
What changed
The new Substance-based Tax Incentive GloBE Safe Harbour is an optional annual election. A qualifying incentive, or part of it, may be added to adjusted covered taxes, potentially increasing Brazil’s jurisdictional effective tax rate and reducing the Additional CSLL. Eligibility depends on the incentive’s legal design, its link to qualifying expenditure or production, the covered tax it reduces and the substance limit based on payroll and tangible assets.
What multinational groups should do
- Map each Brazilian incentive by entity, legal basis, expense or production link and covered tax.
- Reconcile the incentive used in the fiscal year to local ledgers and the group’s GloBE data.
- Calculate the substance limit before making the one-year election.
- Retain the legal, accounting and operational evidence supporting the conclusion.
The election may be used for fiscal years beginning on or after 1 January 2026. Receita’s Questions and Answers is administrative guidance and does not override the law or regulations.
Legal status: binding regulatory amendment with an optional annual election.
Official sources: Receita Federal regulatory update; Receita Federal Questions and Answers; Law No. 15,079/2024.