For multinational groups IN and Declaratory Act regulate complementary tax for companies with annual revenue exceeding €750 million
Last Tuesday (26), the Federal Revenue published the Normative Instruction RFB No. 2,259, of 2025, and the Executive Declaratory Act Cosit No. 1, of 2025, with the objective of updating the rules of the Additional Social Contribution on Net Income (CSLL), applicable to multinational groups with annual consolidated revenue equal to or greater than €750 million.
The changes aim to adapt Brazilian
legislation to the Global Anti-Base Erosion dataset Rules (GloBe) of the Organization for Economic Cooperation and Development (OECD), promoting greater international alignment and legal certainty for taxpayers.
The CSLL Surcharge was established by Law No. 15,079 of 2024, as part of the adoption of the Qualified Domestic Minimum Top-up Tax (QDMTT). This measure is part of the context of the OECD Pillar Two, which defines global minimum taxation standards for large business groups.
With the new Normative Instruction
the IRS made two important adjustments:
Update of the fine limit: the previous version of 7 ways to speed up web page loading the rule provided for a maximum fine limit of R$10 million. With the publication of the new law, this amount was reduced to R$5 million, and the IRS adjusted the Normative Instruction to reflect this change;
Definition of Fiscal Year: the standard has improved for multinational groups the concept of “Fiscal Year”, making it more consistent with the model used by the OECD in the GloBE Rules, which makes it easier for multinational groups to apply the criteria.
Furthermore the Executive Declaratory
Act Cosit No. 1 of 2025 provides guidance on fresh list the exchange. Rate to be used when converting amounts defined in euros to reais. Since international rules set various. Limits on foreign currency. Such as the €750 million revenue ceiling. It is necessary to ensure a uniform conversion criterion.
According to the act, the amounts must. Be converted based on the average exchange rate for December. ublished by the European Central Bank. This rate will be applied to fiscal years beginning in the following calendar year, ensuring predictability and compliance with global standards.
Another point is that the Federal Revenue Service. Will publish the converted values annually. With the aim of providing legal certainty and facilitating compliance with tax obligations by the companies covered.
International context and impact for companies
The new rules reinforce Brazil’s commitment. To international initiatives to combat tax base erosion and profit shifting. Practices that affect global tax equity. By following the OECD and Inclusive Framework model. The country seeks to ensure greater tax transparency and equality in international competition.
Multinational companies in scope
must review their accounting. Structures and practices to ensure compliance. With the CSLL Surcharge, observing the updated criteria and for multinational groups currency conversion rules.