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Global minimum tax in Brazil: the CSLL surcharge (Adicional da CSLL) for groups with EUR 750 million of revenue

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Last verified: 2026-10-27 · Status: Changing

Brazil implemented the OECD and G20 Pillar Two minimum tax through a surcharge on the social contribution on net profit (Adicional da CSLL), created by Law 15,079 of 27 December 2024 and in force from 1 January 2025. It applies to multinational groups with consolidated revenue of at least EUR 750 million in at least 2 of the 4 prior fiscal years, and tops up the Brazilian effective rate to 15 percent, after payroll and tangible asset carve outs; it is designed as a qualified domestic minimum top up tax. The surcharge is due by the last business day of the seventh month after the fiscal year ends, and filing failures cost up to 10 percent of revenue capped at R$5,000,000.

USD figures use the Banco Central do Brasil PTAX selling rate of R$5.5007 per US dollar for 26 October 2026, the latest rate published when this page was verified. Conversions are for orientation only; the rate on the day of each FX contract will differ.

Key facts

Minimum effective rate targeted by the Adicional da CSLL15 %Law 15,079/2024 art. 2, as of 2026-10-27 · in force
Consolidated group revenue threshold (2 of 4 prior years)750,000,000 EURLaw 15,079/2024 art. 4, as of 2026-10-27 · in force
Fiscal years from which the surcharge applies2025-01-01 dateLaw 15,079/2024 art. 43, as of 2026-10-27 · in force
Payroll carve out for 20269.4 %Law 15,079/2024 Annex VI, as of 2026-10-27 · in force
Tangible asset carve out for 20267.4 %Law 15,079/2024 Annex VII, as of 2026-10-27 · in force
Cap on each information penalty5,000,000 BRLLaw 15,079/2024 art. 35, as of 2026-10-27 · in force

The rule

1. Creation and purpose: Law 15,079 creates the Adicional da CSLL as part of adapting Brazilian law to the Global Anti Base Erosion (GloBE) rules, to ensure minimum effective taxation of 15 percent. It amends Laws 9,430/1996 and 12,973/2014.Law 15,079 of 27 December 2024, Arts. 1 and 2, 2024-12-27 official text · verified 2026-10-27 · changed: The surcharge was first instituted by Provisional Measure 1,262 of 3 October 2024; Law 15,079/2024 now governs it, with most provisions in force from 1 January 2025.
2. Scope: constituent entities in Brazil of multinational groups whose consolidated annual revenue is at least EUR 750 million in at least 2 of the 4 fiscal years immediately before the year analysed.Law 15,079/2024, Art. 4, 2024-12-27 official text · verified 2026-10-27
3. Euro conversion: the EUR thresholds are converted at the December average rate of the European Central Bank, applied to fiscal years beginning in the following calendar year, and the Federal Revenue publishes the real amounts each year by executive declaratory act (ADE Cosit 12 of 19 March 2026 is cited for the current values).Federal Revenue, Questions and Answers on the Adicional da CSLL, part 1 (published 1 October 2026), citing Law 15,079/2024 art. 3 item I and IN RFB 2,228/2024 art. 2 §§ 5 to 7, Questions on the revenue threshold and its conversion, 2026-10-01 official text · verified 2026-10-27
4. Who pays: the top up is allocated to Brazilian constituent entities with excess profit, in proportion to their excess profit times the gap between 15 percent and the effective rate; failing that, by net equity. The group may appoint one Brazilian entity to pay for all, the others being jointly liable. Entities that are not otherwise CSLL taxpayers are treated as such for the surcharge.
Cost to do it: 15 percent minus the effective rate, on excess profit after carve outs
Example: Excess profit R$100,000,000 at a 10 percent effective rate: surcharge R$5,000,000 / Same: about US$908,975.22Law 15,079/2024, Art. 30 §§ 1, 3, 4 and 5; art. 33 sole paragraph, 2024-12-27 official text · verified 2026-10-27
5. Substance based income exclusion: a payroll carve out of 5 percent of eligible payroll costs and a tangible asset carve out of 5 percent of eligible carrying value, with transitional higher percentages: payroll 9.6 percent for 2025, 9.4 percent for 2026, 9.2 percent for 2027, falling to 5.8 percent for 2032; tangible assets 7.6 percent for 2025, 7.4 percent for 2026, 7.2 percent for 2027, falling to 5.4 percent for 2032.Law 15,079/2024, Arts. 24 and 25; Annexes VI and VII, 2024-12-27 official text · verified 2026-10-27
6. Payment: the surcharge is due by the last business day of the seventh month following the end of the fiscal year.Law 15,079/2024, Art. 33, 2024-12-27 official text · verified 2026-10-27
7. Information and regulation: constituent entities must provide the information needed to compute the surcharge under a Federal Revenue normative act, and one entity may file for the group. The Federal Revenue regulates the law consistently with OECD reference documents and the requirements for a qualified domestic minimum top up tax (QDMTT); Normative Instruction RFB 2,228 of 3 October 2024 is the regulation, amended in 2025 and 2026.Law 15,079/2024, Art. 3 § 1; arts. 34 and 41, 2024-12-27 official text · verified 2026-10-27
8. Penalties for Brazilian entities: late or missing information, 0.2 percent of the year's total revenue per month or fraction, capped at 10 percent of revenue and R$5,000,000; omitted or incorrect information, 5 percent of the amount concerned, minimum R$20,000 and cap R$5,000,000. The late filing penalty is cut by 90 percent if filed within 30 days, 75 percent within 60 days, 50 percent before any ex officio procedure and 25 percent within a notice deadline; an incorrect item corrected before any ex officio procedure carries no penalty.
Cost to do it: Up to R$5,000,000 per failure
Example: Revenue R$1,000,000,000, filing 3 months late: 0.6 percent = R$6,000,000, capped at R$5,000,000 / Same: capped at about US$908,975.22Law 15,079/2024, Art. 35, 2024-12-27 official text · verified 2026-10-27
YearPayrollTangible assets
20259.6%7.6%
20269.4%7.4%
20279.2%7.2%
20289.0%7.0%
20298.2%6.6%
20307.4%6.2%
20316.6%5.8%
20325.8%5.4%
After 20325%5%

Transitional carve out percentages (Law 15,079/2024 Annexes VI and VII)

Worked example

  • A Brazilian subsidiary of a group with EUR 2 billion revenue enjoys an incentive that brings its GloBE effective rate to 10 percent. After carve outs, its excess profit is R$100,000,000. The surcharge is 15 percent minus 10 percent, 5 percent, of R$100,000,000: R$5,000,000 (US$908,975.22), payable by the last business day of July of the following year for a calendar year company.
  • A subsidiary paying the standard 34 percent IRPJ and CSLL with no incentives will normally show an effective rate above 15 percent and owe no surcharge, but still has to file the required information.

Step by step

  1. 1. Test the group revenue threshold for each fiscal year using the four prior years and the published real equivalents.
  2. 2. Compute the Brazilian jurisdiction's GloBE income and covered taxes, then the effective rate, with the carve outs for the year.
  3. 3. Identify incentives (for example regional income tax reductions) that may push the effective rate below 15 percent.
  4. 4. Decide whether one Brazilian entity will file and pay for all.
  5. 5. Calendar the payment for the last business day of the seventh month after year end, and the information filing under IN RFB 2,228.

Common traps

  • Groups with all constituents in Brazil paying 34 percent still have filing duties; late filing is penalized as a share of revenue.
  • Regional and R&D incentives can create a top up liability, partly clawing back the benefit for in scope groups.
  • The EUR threshold is converted at the prior December ECB average, so currency moves can bring a group into scope.
  • IN RFB 2,228 has been amended several times; check the version in force for each fiscal year.

Sources

Related pages

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