Pillar Two in Brazil
Brazil has implemented OECD Pillar Two through Lei n.º 15.079, de 27 de dezembro de 2024. Each applies to fiscal years beginning on or after the respective date: the QDMTT from 2025-01-01.
Implementation Timeline
Each rule applies to fiscal years beginning on or after the date shown.
Quick reference
| Rule | Effective date | Status |
|---|---|---|
| IIR — Income Inclusion Rule | — | Not adopted |
| UTPR — Undertaxed Profits Rule | — | Not adopted |
| QDMTT — Qualified Domestic Minimum Top-up Tax | Fiscal years beginning on or after 2025-01-01 | Newly in force OECD qualified |
| QDMTT Safe Harbour | Available alongside the QDMTT | Case-by-case |
Implementing legislation
- Lei n.º 15.079, de 27 de dezembro de 2024 — QDMTT introduction 법률 — 2024-12-27 promulgated
- IIR · UTPR — not yet announced
Practical implications
MNE groups with constituent entities in Brazil are subject to Brazil's QDMTT for fiscal years beginning on or after 2025-01-01. Where the conditions of the QDMTT Safe Harbour are met, the IIR/UTPR computation at the parent jurisdictions may be exempted, reducing the burden of dual computation.
Recent legislative developments
- 2024-12-27: Lei n.º 15.079 promulgated — QDMTT introduction (2025-01-01 in force)
Related terms
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- OECD Inclusive Framework — Updated Central Record for Purposes of the Global Minimum Tax, approved 2026-05-11 (current as at 2026-05-01). OECD Global Minimum Tax
- Receita Federal do Brasil (RFB) — Brazil 연방Tax Authority Pillar Two guidance. www.gov.br/receitafederal
- Planalto — Brazil official legislation database. www.planalto.gov.br
Disclaimer
This page is reference information prepared as of 2026-05-28 by synthesising the primary sources listed above, and is not legal or tax advice. Before applying any of this material in practice, please:
- Verify the latest legislation, administrative guidance, and tax authority notices
- Obtain review by a qualified Pillar Two specialist
- Reassess applicability against the specific facts and circumstances of the group
Translation note. The authoritative version of this page is the Korean original (국가별 현황 › 브라질). This English version is provided for accessibility and may not capture every nuance of the original sources. Where precision matters, please refer to the Korean original or to the source legislation in its original language.