On Thursday (December 19), the Senate approved Bill No. 3,817/24, which establishes a 15% effective minimum tax on income applicable to multinational companies operating in Brazil, through an additional Social Contribution on Net Profit (CSLL). The bill now awaits presidential sanction.

The PL 3,817/24 aligns Brazilian tax legislation with the OECD’s Global Anti-Base Erosion (GloBE) Rules, setting a floor for global tax competition and preventing large multinational groups from shifting profits to low-tax jurisdictions (such as tax havens).

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Who Is Affected?

This new minimum tax applies only to multinational groups that have annual revenues of at least EUR 750 million (approximately R$ 4.78 billion) in consolidated financial statements of the ultimate parent entity in at least two of the four fiscal years immediately preceding the analyzed year.

The CSLL surcharge, if applicable after specific calculations, will be classified as a Qualified Domestic Minimum Top-Up Tax (QDMTT) under the OECD’s Inclusive Framework and will be levied on the profits of Brazilian companies that are part of multinational groups.

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Impact on Brazilian Companies

Although Brazil’s corporate income tax burden is already well above 15%, some Brazilian companies may still have an effective tax rate below this threshold, particularly if they benefit from:

✔️ Tax incentives;
✔️ Deductions related to goodwill amortization;
✔️ Other reductions in the tax base.

If the bill is approved by the end of this year, the new tax will take effect in the fiscal year 2025, with payments due by the last day of the seventh month following the end of the fiscal year.

We are available to assist with any clarifications regarding this matter.