OECD Pillar Two.
15% global minimum.

How the Pillar Two calculation works

Pillar Two calculates the ETR (Effective Tax Rate) per jurisdiction — not per entity. It divides adjusted covered taxes by the jurisdiction’s net GloBE income. An ETR below 15% triggers the next tests: safe harbours, the substance-based income exclusion and other adjustments. Only after that sequence can the group determine whether a top-up exists and in what amount.

Coordination across the QDMTT, IIR and UTPR

Practical example

Hypothetical example. Assume a group has EUR 100M of GloBE income in Jurisdiction A and EUR 12M of adjusted covered taxes before safe harbours and the substance-based income exclusion. The initial ETR is 12%. The final top-up, its collection mechanism and the collecting jurisdiction depend on the complete GloBE calculation and on the qualified rules actually in force; this example does not assert the current law of Portugal or any other jurisdiction.

The Brazilian QDMTT

Brazil established the CSLL Surtax to operate as a QDMTT. An initial ETR below 15% is only the starting point: after safe harbours, the substance-based income exclusion and other adjustments, any resulting Surtax may be collected in Brazil with priority over qualified foreign charging mechanisms. The final amount cannot be inferred from a nominal rate or the name of an incentive.

Why Brazil created a QDMTT

A QDMTT gives collection priority to the jurisdiction in which low taxation arises. Without a qualified domestic rule, collection may move to an applicable IIR or UTPR in another group jurisdiction. The actual sequence depends on the qualified rules and safe harbours in force in each country.

Worked example

• Entirely hypothetical case: the Brazilian jurisdiction of an in-scope group
• Net GloBE income: BRL 100M
• Adjusted covered taxes: BRL 9M, with no RSGIF addition
• Initial ETR: 9% — a 6% top-up percentage
• Substance-based income exclusion in this example: BRL 20M
• Excess profits: BRL 80M
• With no safe harbour, a zero additional top-up adjustment and before other adjustments: 6% × BRL 80M = BRL 4.8M
• The example shows the order of operations; it is not a SUDENE, SUDAM, Manaus FTZ or real-company case

How to test Brazilian incentives without assuming the outcome

The benefit’s label does not determine the top-up. Article 63 of RFB Normative Instruction 2.228/2024 defines the ETR as adjusted covered taxes divided by the jurisdiction’s net GloBE income. SUDENE, SUDAM, the Manaus Free Trade Zone, R&D benefits and state credits are therefore inputs to classify, not stand-alone conclusions.

Pillar Two compliance obligations

Pillar Two compliance uses related data across three tracks that are not the same obligation: the Brazilian tax payment and DCTFWeb, Brazil’s own detailed information return, and the OECD GIR.

Brazilian payment and DCTFWeb

Article 73, paragraph 4 of RFB Normative Instruction 2.228/2024, as amended by RFB NI 2.319/2026, assigns the CSLL Surtax to the assessment period corresponding to the “sixth month following the end of the Fiscal Year”. For a year ended December 31, 2025, the June 2026 DCTFWeb and DARF 1809 fell due on July 31, 2026. This domestic event is not the GIR.

GIR (GloBE Information Return)

The GIR is the Inclusive Framework’s standardized information return. Paragraph 3 of the September 2026 revised GIR says it is “separate from the requirement to declare and pay taxes” under domestic law. The revision applies to fiscal years beginning on or after December 31, 2025. It does not establish that Brazil has integrated the GIR into the ECF or adopted the same form and calendar.

Brazil’s detailed information obligation

The RFB stated on July 8, 2026 that the obligation was being developed and that, for a fiscal year ended December 31, 2025, it would be required not before June 30, 2027. That is an announced floor, not a fixed deadline. The full official text of RFB NI 2,342/2026 has been reviewed; it does not amend Article 153 or set the final form and deadline of Brazil’s detailed filing. The OECD GIR remains a separate obligation.

Country-by-Country Report (CbCR)

A per-jurisdiction report of revenue, profit, taxes paid, employees and tangible assets. It can supply data for transitional safe-harbour tests, but its figures still need to be reconciled to the GloBE computation.

Master File and Local File

Transfer Pricing documentation may explain adjustments that affect jurisdictional profit, but it does not replace the GloBE trail. The Transfer Pricing and Pillar Two analysis maps the reconciliation.

Filing timeline

September 2026: RSGIF and the transition safe harbour

RFB NI 2,342/2026 in the official RFB Normas system (idAto 153622), also published in the Official Gazette on September 18, 2026, took effect on publication. It updates the reference-document cut-off to instruments approved by the Inclusive Framework through January 2026; that cut-off does not automatically incorporate later documents.

The same instruction extends Article 128 to fiscal years beginning on or before December 31, 2027 and ending no later than June 30, 2029. The simplified ETR threshold is 16% for fiscal years beginning in 2025 and 17% for those beginning in 2026 or 2027. The extension does not remove the requirement to satisfy one of the Article 128 tests and document the result.

For fiscal years beginning on or after January 1, 2026, Articles 143-A to 143-L permit a one-year election to treat a Qualified Tax Incentive, or part of it, as an addition to Adjusted Covered Taxes. The addition is the lower of the IFQ amount used in the fiscal year and the jurisdictional Substance Limit. It changes the numerator before Article 63 and may increase the ETR; it does not guarantee a zero CSLL Surtax.

Articles 143-B to 143-J require incentive-by-incentive qualification. They distinguish expense-based and production-based incentives and exclude, among other items, benefits related to non-covered taxes, excluded income, subsidies outside the stated exception, incentives not generally available and critical features subject to central-government discretion. A production incentive measured by production value rather than physical quantities produced in the jurisdiction does not qualify.

Article 143-L sets a default Substance Limit at 5.5% of the greater of eligible payroll costs and eligible tangible-asset depreciation and depletion. A five-year election permits 1% of the carrying value of eligible tangible assets, excluding land and other non-depreciable assets. This RSGIF limit is distinct from the Substance-based Income Exclusion used in Article 68.

The OECD September 2026 package: four decisions, not four news items

On September 11, 2026, the Inclusive Framework released an implementation package for the global minimum tax. CFO, Tax and Controllership teams can translate each document into a closing decision:

Official sources: revised GIR, Administrative Guidance and Full Legislative Review Terms of Reference.

What CFO, Tax and Controllership should close now

After Brazil’s first payment deadline and the revised GIR, the objective is not another stand-alone spreadsheet. It is evidence that each fact was assigned to the correct entity, period and obligation.

1. Consolidated ETR modeling by jurisdiction — current and projected baseline under Pillar Two, identifying top-up exposure
2. Classifiable inventory of incentives and credits — legal basis, accounting entry, effect on covered taxes and GloBE hypothesis to test
3. Period map — UPE year, jurisdiction fiscal year, DCTFWeb, local detailed filing and GIR version
4. Transfer Pricing reconciliation — source, entity, counterparty, period and possible GloBE-income effect
5. Versioned data dictionary — GIR, CbCR, Master File, Local File and general ledger coordinated without treating the forms as equivalents
6. Bridge from expense to liability and cash — identify which number belongs to each fiscal year and who approved it

For the complete International pillar, see International Tax Planning.