Brazil Sets Rule for Centralized Payment of Additional Social Contribution on Net Profit (Pillar 2 QDMTT) and Simplifies Application of Transitional CbCR Safe Harbour

Brazil's Federal Revenue Service has announced the publication of Normative Instruction RFB No. 2.329 of 18 June 2026, containing amendments to Normative Instruction RFB No. 2.228 of 3 October 2024, which regulates the Additional Social Contribution on Net Profit (CSLL) introduced by Provisional Measure No. 1.262 of 3 October 2024 and Law No. 15.079 of 27 December 2024. The Additional CSLL is meant to meet the requirements of a qualified domestic minimum top-up tax (QDMTT) in line with the…