[ESTABLISHING A BUSINESS ENTITY IN BRAZIL] 76
CSLL, entities which are part of a Multinational Enterprises Group that have earned annual revenues of at least EUR 750 million in the Consolidated Financial Statements of the Ultimate Parent Entity in at least two of the four fiscal years immediately preceding the year under analysis may be subject to the additional CSLL. To date, Brazilian tax authorities have not issued any official guidance regarding the implementation of the other Pillar 2 mechanisms, namely the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR).
ILN Corporate Group – Establishing a Business Entity Series
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