INSUBCONTINENT EXCLUSIVE:
Brazil plans to introduce a 15% minimum tax rate for multinational companies starting in 2025
Erosion and Profit Shifting (BEPS) project
BEPS aims to combat tax planning strategies that exploit gaps in tax rules to shift profits artificially.Caio Malpighi, a tax lawyer at VBSO
Advogados, explains the purpose of this global tax reform
It seeks to ensure large multinational groups pay at least 15% tax, regardless of where they operate.In addition, the goal is to prevent
companies from moving profits to low-tax jurisdictions
This practice often harms tax collection in countries where these corporations actually generate value.The additional CSLL will apply to the
adjusted net profit of multinational companies
15% Minimum Rate for Multinationals
The measure includes exclusions based on substantial activities within the country.Companies can exclude part of their profit related to
tangible assets and employee payroll from the additional CSLL calculation
This provision recognizes and rewards real economic activity in Brazil.Key Provisions of the New Tax SystemThe effective tax rate will be
calculated based on the Global Anti-Base Erosion (GloBE) profit
If this rate falls below 15%, the additional CSLL will apply to reach the minimum taxation level.However, this system aims to prevent
companies from artificially reducing their global tax burden
It discourages profit shifting to low-tax jurisdictions as a tax avoidance strategy.Companies failing to comply with reporting requirements
face significant penalties
omitted or incorrect information, with a minimum of R$20,000 ($3,600)
The measure offers reduced penalties for companies that correct their information within specific timeframes.In short, this tax reform
represents a significant shift in global corporate taxation
It aims to create a fairer system and ensure multinational companies contribute their share to public finances.
