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乐鱼(Leyu)体育官网 article: Brazil鈥檚 Pillar Two rules require companies to be proactive

Complexity of the tax system necessitates caution in preparing for the application of the new rules

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April 22, 2025

Brazil鈥檚 federal government in October 2024 enacted a provisional measure, which is a type of legal rule that takes immediate effect as a law but requires subsequent confirmation by Congress. Simultaneously, the government presented a Project of Law to Congress with the same contents. Along with the provisional measure, the federal tax authorities (RFB) issued Normative Instruction #2,228/2024 to complement the regulation.

By mid-December, Congress approved the Project of Law, and in the last week of 2024, the president approved and issued Law #15,079/2024. This law included a few modifications when compared to the Provisional Measure, mainly to improve certain aspects of the rules. At the same time, the RFB released a new Normative Instruction (#2,245/2024) to adapt the previous one to the changes in law and to improve specific regulatory points.

Law #15,079/2024 represents a significant change in Brazilian tax policy, aligning it with international standards and addressing issues related to base erosion and profit shifting. Companies operating in Brazil must be proactive in understanding and complying with the new rules to avoid penalties and ensure smooth operations. This is particularly important in Brazil due to the complexity of its tax system, which necessitates even more caution in preparing for the application of the new rules.

Read an April 2025 article* prepared by 乐鱼(Leyu)体育官网 tax professionals

*Reproduced with permission from Tax Management International Journal, 4/1/2025. Copyright @ 2025 by Bloomberg Industry Group, Inc. (800-372-1033) 聽http://www.bloombergindustry.com

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