GloBE Country Guide: Brazil

Summary

Status Enacted Law
LawOn October 3, 2024, Brazil issued Provisional Measure No. 1,262, and Normative Instruction No. 2,228 of October 3, 2024, to introduce a Domestic Minimum Tax from January 1, 2025.

On December 30, 2024, Brazil’s President enacted Law No. 15,079, of December 27, 2024, that repeats (with minor amendments) Provisional Measure No. 1,262, of October 3, 2024, to introduce a Domestic Minimum Tax from January 1, 2025.

On December 31, 2024, Normative Instruction No. 2245, of December 30, 2024 was issued which implements the detailed regulations for the provisions of the domestic minimum tax as provided in Normative Instruction No. 2,228, of October 3, 2024, with a number of amendments.
Effective DateFinancial years beginning on or after January 1, 2025
IIRNo
UTPRNo
QDMTTYes (2025)
Filing DeadlinesNot Provided
Safe HarboursTransitional CbCR Safe Harbour, and the Simplified calculation for Non-Material Constituent Entities Safe Harbour.

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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