On Oct. 3, BRZ Tax adopted rules re social contribution on net profit.
BRZ Tax issued Instruction RFB 2228/2024 provides for the social contribution on net profit in order to align Brazilian legislation to the global rules against tax base erosion.
Instruction 2228 governs the Additional social contribution on net profit (CSLL).
It set minimum taxation of 15% for process of adapting BRZ legislation to global rules against base erosion: Globe Rules, Global Anti-Base Erosion Rules, and GloBE Rules/
Said global rules prepared by Inclusive Framework on Base Erosion and Profit Shifting.
Prepared under the coordination of the OECD and the Group of Twenty, G20.
Instruction applies to constituent entities of a multinational group of companies that have earned annual revenues of at least seven hundred and fifty million euros.
This annual revenue threshold in consolidated financial statements of final investing entity in at least two of the four fiscal years immediately preceding the one analyzed.
If one or more of the fiscal years refer to a period other than twelve months, for each of these fiscal years the limit of 750 million euros will be adjusted proportionally.
Effectiveness
Instruction comes into force on date of its publication and take effect on Jan. 1, 2025.
