Pillar Two in Brazil: the Additional CSLL for multinational subsidiaries

Brazil adopted the OECD global minimum tax through its own instrument: an Additional CSLL that works as a qualified domestic minimum top-up tax (QDMTT). It has applied since fiscal year 2025. The first return and payment, for 2025, were due in mid-2026. For the Brazilian subsidiaries of large multinational groups, Pillar Two is no longer a project at headquarters: it is a local compliance routine with its own deadlines, payment code and penalties. This article explains who is in scope, how the Additional CSLL is calculated and paid, and what the Brazilian finance team needs in place before the next cycle.

What Brazil enacted

Law 15,079/2024 created the Additional CSLL (Adicional da Contribuição Social sobre o Lucro Líquido) as part of adapting Brazilian law to the OECD Global Anti-Base Erosion Rules (GloBE rules). Its purpose, stated in article 2, is to ensure a minimum effective tax rate of 15%. The law took effect for this purpose from January 1, 2025 (article 43).

The law leaves much of the detail to the Federal Revenue, and requires those rules to follow the OECD Model Rules, Commentary and Administrative Guidance, so that the Additional CSLL qualifies as a QDMTT (article 3). The Federal Revenue’s main regulation is Normative Instruction RFB 2,228/2024. In April 2026, Normative Instruction RFB 2,319/2026 set the reporting and payment procedures.

The choice of a domestic top-up tax matters for the group. Where a jurisdiction applies a qualified QDMTT, any top-up tax on profits earned there is, as a rule, collected locally, and it reduces the top-up the parent’s jurisdiction would otherwise collect under the income inclusion rule. For Pillar Two, Brazil keeps the tax on Brazilian profits.

Who is in scope

The Additional CSLL applies to constituent entities of a multinational group with annual revenue of €750 million or more in the consolidated financial statements of the ultimate parent entity, in at least two of the four fiscal years immediately before the year being analyzed (article 4). This is the same threshold as the OECD rules, so a group that is in scope for Pillar Two elsewhere will, as a rule, also be in scope in Brazil.

The law also reaches entities in Brazil that are not ordinarily CSLL taxpayers: for the Additional CSLL, they are treated as taxpayers (article 33, sole paragraph).

Brazil’s rate is 34%. Why would there be a top-up?

The combined nominal rate of corporate income tax (IRPJ) and the Social Contribution on Net Income (CSLL) is 34% for most companies, far above 15%. Many groups therefore assume Brazil will never generate top-up tax. That may be true, but it has to be demonstrated, and it is not guaranteed.

The test is not the nominal rate. It is the GloBE effective tax rate per jurisdiction: covered taxes divided by GloBE income, both calculated with the adjustments in the law and its annexes. Regional tax incentives, special regimes, deductions and timing differences can bring the effective rate measured under GloBE well below the nominal rate. That is why the analysis has to be done with the subsidiary’s actual numbers, year by year.

How the top-up is calculated and allocated

In simplified terms, the Additional CSLL for Brazil is the top-up percentage (15% minus the jurisdiction’s effective rate, when positive) applied to the excess profit. Excess profit is GloBE income minus the substance-based income exclusion, which reflects payroll and tangible assets in Brazil (articles 20, 21 and 28).

The resulting amount is allocated among the group’s constituent entities in Brazil that have excess profits, in proportion to their excess profits multiplied by the difference between 15% and their own effective rate (article 30). The group may instead opt to assign the whole Brazilian Additional CSLL to a single constituent entity, as taxpayer. In that case, the other entities in Brazil remain jointly liable for the amount due (article 30, paragraphs 4 and 5).

Reporting and payment: the calendar

For a calendar-year group, the cycle for fiscal year 2026 therefore points to reporting in the DCTFWeb for June 2027 and payment by the last business day of July 2027. Beyond the payment itself, the constituent entities must provide all information needed to calculate the Additional CSLL, as set by the Federal Revenue, and the rules may allow a single entity of the group to file for all (article 34).

Penalties for missing or wrong information

The penalties are significant and apply to the constituent entities located in Brazil (article 35):

• Late or missing information: 0.2% per month or fraction of the total revenue for the fiscal year concerned, capped at 10% and at R$5 million.
• Incorrect or omitted amounts: 5% of the amount omitted or incorrect, with a minimum of R$20,000 and a maximum of R$5 million.

The late-filing penalty is reduced by 90% if the information is filed within 30 days after the deadline, by 75% within 60 days, and by 50% if filed late but before any tax audit begins.

What the Brazilian subsidiary needs in place

Pillar Two calculations are usually run at group level, often by headquarters or a Big Four provider. Even so, a Brazilian data trail has to feed them, and the local filing and payment are the subsidiary’s responsibility. A practical checklist:

1. Confirm scope and the group’s elections, including whether a single Brazilian entity will be the taxpayer for the whole jurisdiction, and document that decision.
2. Map the Brazilian data the GloBE calculation needs: local accounts reconciled to the group reporting package, current and deferred taxes, payroll and tangible assets for the substance-based exclusion, and any incentives.
3. Reconcile BR GAAP and the group’s accounting framework. GloBE income starts from the financial accounts used for consolidation, adjusted as the law requires. Differences between the local books and the reporting package must be explained.
4. Build the calendar into the month-end close: DCTFWeb in the sixth month, payment under code 1809 in the seventh, and the information return within the deadlines the Federal Revenue sets.
5. Keep evidence of each figure sent to headquarters. Penalties are based on revenue, not on the tax due, so a reporting error can cost more than the top-up itself.

Pillar Two also interacts with other decisions about the Brazilian operation, such as profit distribution. See our article on Brazil’s 10% tax on dividends paid abroad.

How Solidy can help

Solidy already serves subsidiaries of multinational companies in Brazil. Our consultants prepare the local data that group Pillar Two calculations depend on, reconcile BR GAAP with group reporting, and run the DCTFWeb filing and payment calendar so that the Brazilian entity meets its deadlines. Talk to our consultants.