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21 October 2024

Monday, November 4 | Brazil's OECD Alignment - Pillar Two and the arm's length principle (4 pm CET; 10 am ET)

On 3 October 2024, Brazil introduced draft legislation (Provisional Measure 1,262), which would implement a Qualified Domestic Minimum Top-up Tax (QDMTT) in Brazil as a potential first step toward fuller adoption of the Pillar Two global minimum tax rules. This represents a fundamental change to the taxation of Brazilian companies in-scope for Pillar Two and is proposed to be effective as of 1 January 2025. Brazilian companies are also having to adapt to the practical challenges from the first year of mandatory adoption of the arm’s length principle.

Our panel will discuss these two legislative developments, the outlook for further reform and how companies can best position themselves to manage the impacts of these changes. The topics of this webcast are relevant for both Brazilian parented companies and non-Brazilian multinationals with operations in Brazil.

During this 60-minute webcast, EY panelists will be joined by Daniel Loria, Director of the Extraordinary Secretariat for Tax Reform at the Ministry of Finance, Brazil, to examine:

  • Key aspects of Provisional Measure 1,262 and the introduction of a QDMTT in Brazil
  • Potential differences between the proposed Brazilian Pillar Two rules and the adoption in other Pillar Two jurisdictions
  • Preparatory steps to be considered and how companies should prepare for adoption
  • The operational, systems and tax challenges companies have faced with the adoption of the arm's length principle in Brazil and approaches to manage the impact

Date: Monday, 4 November 2024

Time: 4:00 p.m. – 5:00 p.m. CET; 10:00 a.m. – 11:00 a.m. ET

Registration: Register for this event.

Panelists

  • Daniel Loria, Director of the Extraordinary Secretariat for Tax Reform at the Ministry of Finance, Brazil
  • Gustavo Carmona, EY Latin America International Tax and Transaction Services Deputy Leader
  • Katherine Pinzon, EY Americas Transfer Pricing Leader
  • Priscila Vergueiro, Partner, International Tax and Transaction Services, Ernst & Young Assessoria Empresarial Ltda.

Moderator

  • Jose Murillo, EY Americas International Tax and Transaction Services Leader

CPE credit offered: 1.2. See CPE FAQ for more information.

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Document ID: 2024-1930

 
 

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