Federal Revenue updates minimum taxation rules for multinationals in Brazil

New regulatory instruction aligns Brazilian legislation with OECD guidelines and strengthens the protection of the national tax base

The Brazilian Federal Revenue Service published, on October 3, 2025, an important update to the minimum taxation rules applicable to multinational companies operating in Brazil. The measure aligns national legislation with the new guidelines of the Organisation for Economic Co-operation and Development (OECD), in the context of the Global Anti-Base Erosion Rules (GloBE Rules)

What has changed?

The update, set forth in RFB Regulatory Instruction No. 2,282/2025, enhances the minimum taxation model introduced in the country through the CSLL Additional, in accordance with Law No. 15,079/2024. This surtax represents the adoption of the so-called Minimum Domestic Qualified Supplementary Tax (QDMTT) – a mechanism that allows Brazil to take priority in taxing multinational groups that are subject to a reduced tax burden.

With these changes, Brazil aligns itself with the international tax practices under OECD Pillar Two.
Among the most relevant changes, the following stand out:

Furthermore, the regulation also covers topics such as the treatment of the fiscal year of entities, the definition of accounting standards, business combinations, the correct use of the concept of jurisdiction, and the correction of duplications in the application of Withholding Income Tax (IRRF) on Interest on Equity (JCP)

Tax Support

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