International Tax Newsletter de July/26

Pillar 2: Federal Revenue Service releases guidelines on Additional CSLL

The Federal Revenue Service sent a communication via e-CAC to several taxpayers with clarifications on the collection, declaration and accessory obligations related to Pillar 2 in Brazil.

The guidelines refer to the CSLL Supplement, instituted by Law No. 15,079/2024, which implemented the Qualified Minimum Domestic Complementary Tax (QDMTT) in Brazil, in alignment with the OECD GloBE Rules.

The tax applies to entities that are part of multinational groups with consolidated revenues equal to or greater than €750 million in at least two of the last four fiscal years, with the aim of ensuring a minimum effective taxation of 15%.

• The deadline for payment of the tax for the 2025 fiscal year;
• The form of reporting in the DCTFWeb;
• Confirmation that the future accessory obligation related to the CSLL Additional should not be required before 06/30/2027.

It is important to note that the receipt of this communication does not necessarily imply an obligation to pay, fall under the regime or requirement to calculate the Additional CSLL.

The guidelines provide greater clarity on the first compliance milestones of the Brazilian global minimum taxation regime (Pillar 2). In this context, it is recommended that the multinational groups potentially covered evaluate, if they have not already done so, their calculation processes, tax governance and data preparation to meet the deadlines for collection, reporting in the DCTFWeb and future ancillary obligations.

ECF 2026: companies must submit a statement by the end of July

Companies required to submit the 2026 Tax Accounting Bookkeeping (ECF) must submit the statement by Friday (31), the last business day of the month. The accessory obligation, administered by the Federal Revenue Service, gathers information for the calendar year 2025 and is used to demonstrate the calculation of Corporate Income Tax (IRPJ) and Social Contribution on Net Income (CSLL), in addition to allowing the cross-checking of data with other statements submitted by companies.

The ECF must be submitted by legal entities required to complete the bookkeeping, including companies under the Actual Profit, Presumed Profit and Arbitrated Profit regimes, as well as equivalent, immune and exempt entities, according to the rules established by tax legislation.

Late submission or submission with incorrect information can generate inconsistencies in the Federal Revenue Service environment, since the data declared in the ECF are compared with information provided in other ancillary obligations, such as Digital Accounting Bookkeeping (ECD) and tax returns.

U.S. confirms 25% tariff on Brazilian products

The United States made official on July 16th the application of an additional tariff of 25% on part of Brazilian imports. The decision was announced by the U.S. government after the conclusion of a trade investigation conducted by the Office of the U.S. Trade Representative (USTR), which evaluated Brazilian trade practices related to topics such as digital commerce, the Pix payment system, ethanol, intellectual property, and tariff barriers. The measure came into force on July 22nd.

Despite the surcharge, the U.S. government released a list of about 2,100 exceptions, preserving products considered strategic for the American market, such as coffee, beef, orange juice, fresh oranges and components used in the manufacture of aircraft.

Government releases R$ 18.5 billion in credit for companies affected by the US tariff

The federal government announced a new support package for companies impacted by the increase in tariffs imposed by the United States on Brazilian products. The third stage of the Sovereign Brazil Plan will provide R$ 18.5 billion in credit lines aimed at exporters and sectors considered strategic for the national economy.

The announcement was made on the same day that the additional tariff of 25% applied by the United States on part of Brazilian exports came into force. According to the Ministry of Development, Industry, Commerce and Services (MDIC), the U.S. measure should affect about 15% of the Brazilian export basket destined for the U.S. market, equivalent to approximately US$ 5.8 billion in exports.

Bill authorizes the creation of a fund to expand credit to exporters

A bill under analysis in the Chamber of Deputies proposes the creation of a fund aimed at expanding access to credit for Brazilian exporting companies. The measure aims to strengthen export financing, facilitate productive investments and increase the competitiveness of national companies in the international market.

Bill No. 5,961/2025, authored by the Federal Senate, authorizes the creation of the Export Credit Fund (FCE), which will be able to finance pre- and post-shipment operations, in addition to offering resources for working capital, acquisition of machinery, equipment and modernization of the productive structure of exporting companies.

According to the proposal, the FCE will be supplied with resources from the Federal Budget, contracts signed with public entities, returns on financing granted and funds from the Export Guarantee Fund (FGE). The resources should be allocated exclusively to reimbursable financing, respecting criteria of financial sustainability and transparency.

The text also establishes limits for administrative expenses. Up to 2% of the fund's equity may be used annually to fund the remuneration of the financial agent responsible for operations and other administrative expenses.

Brazil and Paraguay formalize Mercosur protocol to modernize cargo transport on the border

Brazil and Paraguay formalized, within the scope of the 68th Mercosur Summit, a bilateral protocol to regulate the international transport of smaller cargo in the border region. The agreement was signed in Asunción, on June 29 and 30, 2024, and released by the Federal Revenue Service on July 1, 2024.

The measure has a direct impact on operations carried out in the region of Foz do Iguaçu, Ciudad del Este and Presidente Franco, strategic points of the so-called triple border. According to the Federal Revenue Service, the protocol seeks to provide greater legal certainty to operators, improve local logistics and strengthen customs control over a mode of transport widely used in the region.

In practice, the new agreement seeks to organize an already existing reality in border trade. Companies, carriers, importers, exporters, and logistics operators that work with smaller goods depend on clear rules to reduce the risks of retention, fines, delays, and tax questions.

The protocol also reinforces a trend observed in foreign trade: the modernization of border controls through more coordinated procedures between countries. The signing ends a stage of technical negotiations conducted within the scope of Technical Committee No. 2 and the Technical Subcommittee on Border Controls and Operations of Mercosur, with the participation of the Federal Revenue Service, Customs in Foz do Iguaçu, the National Land Transport Agency, the Ministry of Foreign Affairs, and Brazilian and Paraguayan agencies related to transport and customs administration.

Although the agreement has a regional focus, the topic is of interest to companies from different sectors because it involves the international circulation of goods, tax documentation, customs regularity, and responsibility for the origin, transportation, and destination of cargo.