International Tax Newsletter - June 2026

Centralization of CSLL Additional Payment in Multinational Groups

On June 19, 2026, the Brazilian Federal Revenue Service issued Normative Instruction 2.329, which amended IN N° 2.228/2024 regarding the CSLL Additional (Social Contribution on Net Profit) under the OECD GloBE Rules, with its main purpose being to regulate the operation of the CSLL for multinational groups, allowing the payment to be centralized in a single group entity, in order to provide greater legal certainty and align Brazilian regulations with the GloBE Rules.

The IN also changed the text of Article 153 of IN N° 2.228/2024 to make a future ancillary obligation related to the CSLL Additional explicit, indicating that the Federal Revenue should create or detail a specific ancillary obligation for the additional, requiring information that currently depends on further regulation. In this way, it strengthened the legal basis for the Revenue to establish the ancillary obligation.

Deadlines and payment codes for the CSLL Additional

On June 24, 2026, the Federal Revenue Service released guidelines for Constituent Entities within the scope of Multinational Companies regarding the CSLL Additional tax about the procedures for paying this tax, the future submission of a specific ancillary obligation, and reporting information in DCTFWeb.

According to the Federal Revenue Service, the CSLL Additional must be collected by the last business day of the seventh month after the end of the jurisdiction's fiscal year.
The Revenue also established two collection codes: 1809-02 for centralized payment, when the full amount is collected by a single company, and 1809-01 for individual payment, when each entity collects its own share.

Finally, the Federal Revenue Service stated that it is developing a specific ancillary obligation for calculating the CSLL Additional, and that this will not be required until 18 months after the end of the calculation period. Therefore, groups with a fiscal year ending on 12/31/2025 only have to submit the obligation from 06/30/2027.

The Federal Revenue forbids offsetting tax losses and negative CSLL bases after a change in corporate control and activity

On June 15, 2026, the Federal Revenue Service published Consultation Solution N° 4.018/2026 to reinforce a rule of Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL) that in certain situations, a company loses the right to use accumulated tax losses and CSLL negative bases to offset future profits when cumulatively a change in corporate control and a change in the company's business activity occur.  

Additionally, the Federal Revenue clarified the use of the term “cumulatively,” found in Article 584 of the RIR/2018, since previously some taxpayers argued that the prohibition only applied when the change in corporate control and the change in business activity happened at the same time. However, the Revenue rejected this interpretation, stating that the word “cumulatively” means that both conditions must exist, but not necessarily simultaneously.

No occurrence of exclusion of government grants from the IRPJ and CSLL base 

In the Federal Official Gazette of the Union (DOU), the Federal Revenue Service published Consultation Solution N° 4.015/2026, addressing the taxation of revenues from government grants, arising from Law N° 14.789/2023.

According to the Revenue Service, there is no legal basis to exclude from the calculation of IRPJ and CSLL the revenues from government grants, state tax incentives, and other benefits covered under the new regime of Law N° 14.789/2023 (such as ICSM classified as investment grants).

The Revenue Service states that taxation occurs regardless of whether the grant is classified as operational or investment, and regardless of the tax regime adopted (actual, presumed, or arbitrated profit).

Tax incidence on withdrawal from company acquisition

On June 15, 2026, the Federal Revenue brought Solution of Consultation COSIT N° 88/2026, stating that compensations in cases of withdrawal from company acquisition contracts are subject to IRPJ, CSLL, PIS/Pasep, and Cofins. 

According to the Federal Revenue, the payment is not meant to cover a financial loss; the compensation represents reimbursement for the disappointment of a future expectation, using Article 70 of Law N° 9.430/96 as the legal basis. For this reason, the Revenue likened this situation to the concept of lost profits, which are taxable. 

Adoption of the alphanumeric CNPJ

Starting July 31, 2026, new companies will use a new CNPJ (National Register of Legal Entities) structure, one that will be alphanumeric. The new structure will still have 14 positions, but the first 12 can contain letters (A-Z) and numbers (0-9). The last two characters will continue to be numeric check digits.

The change will only apply to new companies from July 31, 2026. Those who already have a CNPJ won't need to make any changes and will keep their current number.

According to the Revenue, the fully numeric model was approaching the limit of available combinations, and allowing letters drastically increases the possible combinations, preventing the exhaustion of new CNPJ numbers in the future.