{"version":"1","article":{"id":"brazil-globe-substance-incentive-rule-october-2026","slug":"brazil-globe-substance-incentive-rule-october-2026","language":"en","url":"https://haberpaper.com/en/news/brazil-globe-substance-incentive-rule-october-2026","api_url":"https://haberpaper.com/api/v1/articles/brazil-globe-substance-incentive-rule-october-2026?lang=en","title":"Brazil adds a substance-based incentive simplification to its global minimum-tax rules","summary":"The tax authority updated the Additional CSLL rules with an optional GloBE treatment for some expenditure- or production-linked incentives, available from 2026.","category":"fiscal","region":"world","topics":[],"published_at":"2026-10-06T19:41:46+03:00","modified_at":"2026-10-06T19:41:46+03:00","publication_basis":"publication-record","event_period":"2026-10-01","event_period_basis":"event-or-reference-period","sources":[{"name":"Receita Federal do Brasil","url":"https://www.gov.br/receitafederal/pt-br/assuntos/noticias/2026/outubro/receita-federal-atualiza-legislacao-do-adicional-da-csll-e-incorpora-nova-regra-simplificadora","publishedAt":"2026-10-01","checkedAt":"2026-10-06"}],"translations":[{"language":"tr","url":"https://haberpaper.com/tr/news/brazil-globe-substance-incentive-rule-october-2026","api_url":"https://haberpaper.com/api/v1/articles/brazil-globe-substance-incentive-rule-october-2026?lang=tr"},{"language":"en","url":"https://haberpaper.com/en/news/brazil-globe-substance-incentive-rule-october-2026","api_url":"https://haberpaper.com/api/v1/articles/brazil-globe-substance-incentive-rule-october-2026?lang=en"},{"language":"ar","url":"https://haberpaper.com/ar/news/brazil-globe-substance-incentive-rule-october-2026","api_url":"https://haberpaper.com/api/v1/articles/brazil-globe-substance-incentive-rule-october-2026?lang=ar"},{"language":"fr","url":"https://haberpaper.com/fr/news/brazil-globe-substance-incentive-rule-october-2026","api_url":"https://haberpaper.com/api/v1/articles/brazil-globe-substance-incentive-rule-october-2026?lang=fr"},{"language":"es","url":"https://haberpaper.com/es/news/brazil-globe-substance-incentive-rule-october-2026","api_url":"https://haberpaper.com/api/v1/articles/brazil-globe-substance-incentive-rule-october-2026?lang=es"}],"data_types":[],"data":null,"data_compilations":[],"data_downloads":[],"content":{"paragraphs":["Brazil’s Federal Revenue Service updated the rules governing the Additional CSLL applied to multinational enterprise groups. Announced on October 1, the change was made through Normative Instruction 2,342, dated September 15, 2026, amending Instruction 2,228/2024. It incorporates part of the Side-by-Side Package approved by the OECD/G20 Inclusive Framework in January 2026. The update addresses two points: extending a transitional GloBE simplification and adding a simplified option for certain tax incentives linked to substantive business activity.","Under the new option, a multinational group may treat a qualifying tax incentive as an addition to adjusted covered taxes in the relevant jurisdiction. That treatment can raise the calculated effective tax rate and potentially reduce the Additional CSLL due there; it is not an automatic reduction or a blanket exemption for incentives. To qualify, an incentive must be linked to the company’s expenditure or directly to the quantity it produces, and it must actually reduce a tax liability within the scope of the GloBE rules. The amount that can be included is capped at the lower of the incentive used and the jurisdiction’s substance limit.","The substance limit takes account of factors such as payroll and tangible assets. The instruction also excludes incentives that reduce taxes outside the GloBE rules, relate only to income or profits already excluded from the calculation, or take the form of general subsidies or grants. Benefits unavailable to all companies meeting legal requirements are excluded as well, as are incentives whose award depends on government discretion. These boundaries mean the simplified treatment does not cover every tax relief or public-support measure. Eligibility remains subject to a company- and jurisdiction-specific assessment under the amended rules.","Use of the new method is optional. The filing constituent entity can make a one-year election for fiscal years beginning on or after January 1, 2026. Separately, the transitional GloBE simplification is extended to fiscal years that begin by December 31, 2027, excluding years that end after June 30, 2029. The amendment updates Brazil’s domestic implementation of the international minimum-tax framework. The Receita Federal announcement did not identify companies affected, quantify any change in tax liability or forecast additional collections; those outcomes depend on the facts and elections in each case."],"key_points":[],"sections":[]},"text":"The tax authority updated the Additional CSLL rules with an optional GloBE treatment for some expenditure- or production-linked incentives, available from 2026.\n\nBrazil’s Federal Revenue Service updated the rules governing the Additional CSLL applied to multinational enterprise groups. Announced on October 1, the change was made through Normative Instruction 2,342, dated September 15, 2026, amending Instruction 2,228/2024. It incorporates part of the Side-by-Side Package approved by the OECD/G20 Inclusive Framework in January 2026. The update addresses two points: extending a transitional GloBE simplification and adding a simplified option for certain tax incentives linked to substantive business activity.\n\nUnder the new option, a multinational group may treat a qualifying tax incentive as an addition to adjusted covered taxes in the relevant jurisdiction. That treatment can raise the calculated effective tax rate and potentially reduce the Additional CSLL due there; it is not an automatic reduction or a blanket exemption for incentives. To qualify, an incentive must be linked to the company’s expenditure or directly to the quantity it produces, and it must actually reduce a tax liability within the scope of the GloBE rules. The amount that can be included is capped at the lower of the incentive used and the jurisdiction’s substance limit.\n\nThe substance limit takes account of factors such as payroll and tangible assets. The instruction also excludes incentives that reduce taxes outside the GloBE rules, relate only to income or profits already excluded from the calculation, or take the form of general subsidies or grants. Benefits unavailable to all companies meeting legal requirements are excluded as well, as are incentives whose award depends on government discretion. These boundaries mean the simplified treatment does not cover every tax relief or public-support measure. Eligibility remains subject to a company- and jurisdiction-specific assessment under the amended rules.\n\nUse of the new method is optional. The filing constituent entity can make a one-year election for fiscal years beginning on or after January 1, 2026. Separately, the transitional GloBE simplification is extended to fiscal years that begin by December 31, 2027, excluding years that end after June 30, 2029. The amendment updates Brazil’s domestic implementation of the international minimum-tax framework. The Receita Federal announcement did not identify companies affected, quantify any change in tax liability or forecast additional collections; those outcomes depend on the facts and elections in each case.","corrections":[],"editorial_illustration":{"kind":"symbolic-editorial-illustration","documentary":false,"scope":"section","asset_id":"fiscal","url":"https://haberpaper.com/assets/illustrations/fiscal-1536.webp","width":1536,"height":1024,"alt":"Symbolic public finance illustration with a civic building, balanced scale and closed books.","language":"en"},"section_illustration":{"kind":"symbolic-editorial-illustration","documentary":false,"scope":"section","asset_id":"fiscal","url":"https://haberpaper.com/assets/illustrations/fiscal-1536.webp","width":1536,"height":1024,"alt":"Symbolic public finance illustration with a civic building, balanced scale and closed books.","language":"en"}}}