Brazil's Federal Revenue adopts OECD rule for multinational tax incentives

Brazil's Federal Revenue Service (Receita Federal) has incorporated an OECD rule regarding the treatment of specific tax incentives for multinational corporations into its global minimum taxation regulations. This change is detailed in Normative Instruction RFB No. 2,342/2026.

The new regulation introduces the GloBE Simplifier Rule for Substance-Based Tax Incentives (RSGIF). This mechanism allows multinational groups to consider certain qualified tax incentives (IFQ)—specifically those based on expenditures or production—when calculating adjusted covered taxes. This is part of the effort to ensure a minimum effective tax rate of 15% on profits earned in Brazil.

The rule applies to multinational groups with consolidated annual revenues of €750 million or more in at least two of the four preceding fiscal years. The RSGIF option can be applied to fiscal years beginning on or after January 1, 2026. For an incentive to qualify, it must have a direct and clear link to the incentivized investment, and the benefit cannot exceed the amount of the corresponding expenditures.