In an effort to reconcile its tax system with the OECD’s Global Anti-Base Erosion (GloBE) Pillar Two regulations, Brazil issued on October 3, 2024 Provisional Measure 1,262/2024 and Normative Instruction RFB No. 2,228/2024. These legislative and administrative measures introduce an additional Social Contribution on Net Income (CSLL) to ensure a minimum effective tax rate of 15% for multinational enterprises. This move is part of Brazil’s commitment to fair taxation within the global economic framework, which will further its reputation as a transparent and equitable jurisdiction for multinational business operations.
The Brazilian-American Chamber of Commerce was pleased to welcome Bruno Marques Santo, Partner at Finocchio & Ustra Advogados; Daniel Loria, Director at the Extraordinary Secretariat for Tax Reform at the Ministry of Finance of Brazil; and Nathaniel Carden, Partner, International Tax; Tax Controversy & Litigation at Skadden, Arps, Slate, Meagher & Flom LLP to address Brazil’s adoption of the Pillar Two rules, as well as tax mechanisms of Provisional Measure 1,262/2024 and Normative Instruction RFB 2,228/2024.
Opening Remarks:
Will Landers, Partner, BTG Pactual and President & Chairperson of the Board, Brazilian-American Chamber of Commerce
Moderator & Speaker:
Bruno Marques Santo, Tax Partner, Finocchio & Ustra Advogados
Speakers:
Daniel Loria, Director, Ministry of Finance of Brazil – Extraordinary Secretariat for Tax Reform
Nathaniel Carden, Partner, International Tax; Tax Controversy & Litigation, Skadden, Arps, Slate, Meagher & Flom LLP
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