On 19 June 2026, the Brazilian Federal Revenue Service published Normative Instruction (NI) No. 2,329/2026, amending NI No. 2,228/2024, which regulates the Qualified Domestic Minimum Top-up Tax (QDMTT) under the GloBE Rules (Pillar Two).
Our specialists have identified three key points for multinational groups operating in Brazil:
Centralized payment of the QDMTT
The election for this regime is now made through the payment itself, using a specific identification code, with no need to file a separate request. In practice, making the payment correctly formalizes the election.
Fiscal year of the Country-by-Country Report (CbCR) versus local fiscal year
Where the two fiscal years do not coincide, the rule allows taxpayers to choose between the CbCR that ends within the local fiscal year and the one that begins within it.
The Transitional CbCR Safe Harbour is tested using the figures reported in the CbCR, including revenue, profit before income tax, and current taxes. The two criteria may therefore point to two different twelve-month periods, with different financial results, for the same local fiscal year. This may affect the outcome of the De Minimis Test, the Simplified ETR Test, and the Routine Profits Test.
Because the election is irrevocable and applies to all subsequent fiscal years, companies cannot adopt the more favorable criterion year by year. Before making the election, companies should therefore simulate both criteria throughout the transitional period to assess which one more consistently preserves Safe Harbour eligibility.
Ancillary obligation
The third point confirms that information on the Qualified Domestic Minimum Top-up Tax (QDMTT), including the elections made under the NI, will be reported through a dedicated ancillary obligation, to be filed through DCTFWeb. There is as yet no information on the layout adjustments required to accommodate these data.
Further regulations are expected to be published shortly, particularly regarding the deadline for filing the ancillary obligation for the QDMTT.
Glossary
Qualified Domestic Minimum Top-up Tax (QDMTT): Additional contribution introduced as part of Brazil’s implementation of the OECD/G20 Pillar Two framework, aimed at ensuring a minimum level of taxation for large multinational groups.
GloBE Rules (Pillar Two): International tax rules developed by the OECD to establish a global minimum effective tax rate for large multinational enterprise groups.
Normative Instruction (NI): Regulatory instrument issued by the Brazilian Federal Revenue Service to provide guidance on the implementation and application of tax legislation.
Country-by-Country Report (CbCR): Report filed by large multinational groups containing jurisdiction-by-jurisdiction information on revenue, profits, taxes, and other economic indicators.
Transitional CbCR Safe Harbour: Temporary simplification mechanism under the GloBE Rules that allows certain jurisdictions to avoid a full Pillar Two calculation when specified criteria are met.
De Minimis Test: Safe Harbour criterion based on low levels of revenue and profit within a jurisdiction.
Simplified ETR Test: Safe Harbour criterion based on a simplified calculation of the jurisdiction’s effective tax rate.
Routine Profits Test: Safe Harbour criterion that compares profits in a jurisdiction against a measure of routine economic activity.
DCTFWeb: Brazilian electronic tax reporting platform used to file and manage federal tax obligations and related information.
