Brazil · Tax regime
Brazilian Worldwide Tax Regime
Reformed
Last verified July 2026
Reshaped by Lei 14.754/2023 (offshore assets, CFCs and trusts) and Lei 15.270/2025 (the IRPFM minimum tax from 2026). This is a tightening cycle, and we list it because it is the decisive factor in every Brazilian relocation.
Brazil has no non-dom regime, no tax holiday, and no territorial carve-out. It is the only major relocation destination in Latin America that taxes arriving residents on worldwide income from day one with no transition relief — and since 2024 it looks through the offshore structures most UHNW families arrive holding. The passport is cheap; the residency is among the most expensive in the region.
Qualifying routes
—
Tax residency on arrival
attaches immediately on entry with a permanent visa, or after 183 days in 12 months on a temporary one
The facts
- Total landed cost
- not a programme with a fee — the cost is the tax
- Physical presence
- 183 days in a 12-month period for temporary-visa holders; immediate for permanent-visa holders
- Family
- individual
- Permanent residency
- not applicable
- Citizenship
- not applicable
- Language test
- not applicable
- Dual citizenship
- Permitted
- Requirements
- declaration of definitive entry and annual DIRPF filingannual reporting of foreign assets, and to the Banco Central above the CBE thresholdsrestructuring of offshore holdings before arrival if the 15% CFC charge is to be avoided
What can go wrong
- Tax residency attaches immediately on arrival with a permanent visa — there is no 183-day cushion and no arrival-year relief. Restructuring must be complete before you land.
- Lei 14.754/2023 imposes 15% annually on the profits of controlled foreign entities as at 31 December, distributed or not, for anyone holding over 50%. It applies to corporations, LLCs, partnerships and foreign trusts alike.
- Foreign trusts are transparent: assets are treated as the settlor's during life, with fiscal transfer on irrevocability, death, or distribution — whichever comes first. Classic asset-protection trusts do not work here.
- The IRPFM minimum tax from 2026: 0% rising linearly to 10% between BRL 600,000 and BRL 1.2 million of annual income, and 10% above BRL 1.2 million.
- The offshore regularisation amnesty has closed. There is no reduced-penalty route for historic undeclared assets.
- ITCMD inheritance tax is becoming progressive under the 2023 reform; the old 8% ceiling should not be assumed.
- There is no US–Brazil income tax treaty, so US persons face a poorly-relieved overlap.