Brazil Gazettes Provisional Measure Introducing Pillar 2 Global Minimum Taxation

The Brazilian Official Gazette Oct. 3 published Provisional Measure No. 1,262, to ensure 15 percent minimum taxation under the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules. The provisional measure includes measures: 1) implementing an additional social contribution on net income (CSLL) as a Qualified Domestic Minimum Top-up Tax (QDMTT), to ensure 15 percent minimum effective taxation; 2) applying the additional CSLL to the constituent entities of a multinational enterprise (MNE) group that has annual revenue of at least 750 million euros (US$823.3 million) on the ultimate parent’s consolidated financial statements in at least two of the previous four fiscal ...