Map the evidence before making the election.

AdCSLL: determine eligibility before electing the safe harbour

On 1 October, Receita Federal announced Normative Instruction RFB No. 2,342/2026, dated 15 September, which amended the rules for Brazil’s Additional CSLL under the GloBE minimum-tax framework. The regime applies to constituent entities of multinational groups with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding fiscal years.

The new Substance-based Tax Incentive GloBE Safe Harbour allows a qualifying fiscal incentive, or part of it, to be treated as an addition to adjusted covered taxes. This may increase the jurisdictional effective tax rate and reduce the Additional CSLL. The incentive must be linked to qualifying expenditure or production volume and reduce a tax within the GloBE scope. General subsidies, discretionary incentives, incentives involving non-covered taxes and incentives linked only to excluded income do not qualify.

• Map each Brazilian incentive by entity, legal basis, expense or production link and covered tax.
• Reconcile the incentive used in the fiscal year with local ledgers and the group’s GloBE data.
• Calculate the substance limit using the relevant payroll and tangible-asset factors before making the election.

The election is optional, applies for one year and may be used for fiscal years beginning on or after 1 January 2026. Receita’s new Questions and Answers assists interpretation but does not override the law or regulations.

Legal status: binding regulatory amendment with an optional annual election; Receita’s Questions and Answers is administrative guidance.

FGTS debts: compare settlement value before migrating

On 2 October, PGFN announced Settlement Notice PGDAU No. 12/2026 for employers with up to R$45 million in consolidated debts enrolled in the active debt register for FGTS or the social contribution under Complementary Law No. 110/2001. Employers listed by the Ministry of Labour for work analogous to slavery are excluded.

Adhesion opens on 15 October 2026 and closes at 7:00 p.m. Brasília time on 29 January 2027 through Regularize. Active Caixa agreements may be migrated. Discounts may reach 100% of interest not allocated to workers, penalties and legal charges, subject to an overall cap of 65% of the debt. Amounts owed directly to workers cannot be discounted. Termination-related FGTS must be paid in up to 12 instalments; other balances may extend to 108 or 133 instalments depending on the applicant.

Before adhering, reconcile the active-debt register to payroll and FGTS records, identify worker-linked amounts, compare the present value with any existing agreement and document the approval and cash-flow assumptions.

Legal status: binding administrative settlement notice; adhesion is voluntary and subject to its eligibility and payment conditions.

Domestic-violence leave: build a confidential payroll route

On 1 October, the Federal Government approved a binding legal opinion implementing the Supreme Federal Court decision on judicially ordered leave for women facing domestic violence. The employment relationship may be preserved for up to six months. For employees, the employer is responsible for the first 15 days and INSS for the remaining period. The judicial protective order is sufficient for the benefit process, without a new medical examination on the merits.

The benefit has no qualifying period, is not subject to social-security contribution and counts as contribution time. The Ministry of Social Security and INSS were given 15 days from publication of the opinion to regulate the payment process.

HR and payroll should establish a restricted-access workflow covering receipt of the order, the first 15 payroll days, the transition to INSS, benefit-status follow-up and return-to-work controls. The reason for leave should not be exposed in ordinary manager reports or broad payroll files.

Legal status: Supreme Court decision implemented through a binding federal legal opinion; detailed INSS operating rules were still pending as of 5 October.

Split payment: testing is not production

Receita Federal confirmed that controlled integration testing between payment service providers and the public CBS/IBS split-payment platform begins on 15 October 2026. No real transactions will be processed during this phase and participating providers are not subject to penalties.

The initial association-based nomination deadline closed on 2 October. Other payment service providers may enrol from 16 November, with forms and instructions expected from 13 November.

Ordinary taxpayers should not redesign customer settlement flows on the assumption that split payment is already live. Tax and treasury teams should instead confirm their providers’ participation, map the data needed for reconciliation and track how payment events will connect to invoices, CBS/IBS ledgers and exception handling.

Legal status: official implementation notice for a controlled test phase; no production transaction duty was announced for ordinary taxpayers.