Executive summary

On 6 April 2026, the Brazilian Federal Revenue Service (RFB) published Normative Instruction (NI) No. 2,319/2026, introducing guidance on the reporting and payment of the Additional Social Contribution on Net Profit (CSLL) associated with the implementation of the Organization for Economic Co-Operation and Development (OECD) Pillar Two Global Anti-Base Erosion (GloBE) rules in Brazil. Note that the Qualified Domestic Minimum Top-up Tax (QDMTT) was introduced in Brazil as a surplus to the Social Contribution on Profit, referred to as "Additional CSLL." (For background, see EY Global Tax Alert, Brazilian Government publishes Provisional Measure introducing OECD Pillar Two rules, dated 4 October 2024.)

NI No. 2,319/2026 amends two key regulations governing Brazil's Pillar Two compliance framework and electronic tax reporting systems:

• NI No. 2,228/2024 sets out the Brazilian implementation of the GloBE rules.
• NI No. 2,237/2024 regulates the Declaration of Federal Tax Credits and Debts, Brazil's federal electronic system used for reporting and assessing federal tax liabilities and referred to as DCTFWeb.

Key changes introduced by NI No. 2,319/2026

Mandatory reporting in the DCTFWeb

NI No. 2,319/2026 clarifies that the Additional CSLL calculated under the GloBE rules must be reported in the DCTFWeb by the end of the sixth month following the end of the relevant fiscal year for the jurisdiction.

This provision formally connects the technical Pillar Two computation — often performed at group level using international accounting and tax data — with Brazil's domestic electronic tax reporting system.

Formal inclusion of Additional CSLL as a reportable federal tax

The NI also amends NI No. 2,237/2024 to expressly include the Additional CSLL among the federal tax liabilities that must be declared through the DCTFWeb.

As a result, the Additional CSLL is now fully integrated into Brazil's standard compliance and electronic tax collection framework, aligning Pillar Two obligations with existing federal tax reporting processes.

Payment deadline and first collection date

NI no. 2,228/2024 already provided that the Additional CSLL must be paid by the last business day of the seventh month following the end of the fiscal year. In March 2026, the RFB released code 1809 (Additional CSLL — GloBE Rules) as the code to apply for this purpose.

Accordingly, the first payment deadline is 31 July 2026, establishing a clear timeline for affected multinational groups to operationalize compliance with Brazil's Pillar Two top-up tax.

Effective date

NI No. 2,319/2026 entered into force on the date of its publication, immediately amending NIs No. 2,228/2024 and No. 2,237/2024 to consolidate the procedural aspects of declaration, assessment and payment of the Additional CSLL within Brazil's electronic tax systems.

Implications and next steps

NI No. 2,319/2026 represents a significant operational step in Brazil's implementation of the OECD Pillar Two framework. By clarifying reporting timelines and the integration of the Additional CSLL into the DCTFWeb, the RFB has reduced uncertainties around the practical compliance mechanics of the domestic minimum top-up tax.

Multinational groups within scope should consider the following actions, depending on their particular situations:

• Assess the interaction between their global Pillar Two calculations and Brazilian reporting requirements.
• Ensure internal systems are capable of meeting the six-month reporting and seven-month payment deadlines.
• Coordinate Brazilian compliance efforts with global tax, accounting and Pillar Two implementation teams.

Given the technical complexity of the GloBE rules and the tight timelines involved, early planning and alignment across jurisdictions will be critical.