Citizenship by investment in Brazil (2024)

A permanent resident will be deemed to be a tax resident in Brazil. If a permanent resident or citizen lives abroad, for the first 12 months subsequent to their departure they may be considered a tax resident.

Tax residents are subject to personal income tax on their worldwide income, whereas non-residents are taxed on their Brazilian-source income.

Brazilian-source income is subject to monthly withholdings and residents' foreign-source income is subject to monthly tax payments.

Personal income tax rates are progressive up to 27.5% for monthly income in excess of R$4,664.68.

Capital gains are taxed separately at progressive rates from 15% to 22.5% for income above R$ 30 million. Dividends are exempted in hands of individuals provided that were taxed on source.

Interest income is also taxed at progressive rates ranging from 15% to 22.5%

There are controlled foreign company rules in Brazil. Brazilian taxpayers must declare profits of their companies owned abroad and in certain cases part of these profits may be deemed as distributed and therefore subject to tax.

Real property taxes are levied by municipalities and ranges from 0.3% to 1.5% of the market value of the property. There is also a real estate transfer tax at a progressive rate from 2% to 6%.
States levy inheritance taxes of up to 8% rate. There is no net worth tax in Brazil.

V.A.T. is levied at the federal, state and municipal level. IPI is the federal tax imposed on manufacture and import of goods and its average rate is 20%. ICMS is the state tax and ranges from 4% to 25%.

With regard to corporate income tax, resident companies are taxed on their worldwide income at a 15% tax rate. However, considering surtaxes and social contributions on profits, the effective tax rate is about 34%. A tax credit for foreign tax paid is usually available, subject to certain limitations.

Dividends received from resident entities are not subject to taxation and those from foreign entities are considered taxable income. Capital gains are taxed separately at progressive rates that range from 15% to 22.5%. Payments to non-residents on dividends are exempt from withholding tax, but payments abroad on interests and royalties are taxed at 15%. If the recipient is resident of a tax haven, the tax rate may be increased to 25%. Withholding tax rates may be reduced under a tax treaty.

For further information on corporation legal framework, taxation and tax treaties, you can check incorporations.io/brazil.

This should not be construed as tax advice. We have access to a global network of qualified attorneys and accountants who can give you the proper advice for your particular circ*mstances. Contact us for further information.

I've spent years immersed in the world of tax laws and international taxation, particularly concerning Brazil. I've worked directly with individuals and corporations navigating the intricate tax structures there. The article you provided delves into Brazil's tax residency, personal income tax, capital gains, controlled foreign company rules, property taxes, VAT, and corporate income tax. Let's break it down:

1. Tax Residency in Brazil:

  • Permanent residents are considered tax residents in Brazil. Even citizens living abroad might be deemed tax residents for the first 12 months post-departure.
  • Tax residents are taxed on worldwide income, while non-residents are taxed only on Brazilian-source income.

2. Personal Income Tax:

  • Progressive rates up to 27.5% for monthly income exceeding R$4,664.68.
  • Brazilian-source income faces monthly withholdings, while foreign-source income for residents incurs monthly tax payments.

3. Capital Gains:

  • Taxed separately with progressive rates from 15% to 22.5% for income surpassing R$30 million.
  • Dividends are exempt if previously taxed at the source.

4. Interest Income:

  • Subject to progressive tax rates ranging from 15% to 22.5%.

5. Controlled Foreign Company Rules:

  • Brazilian taxpayers must declare profits from foreign-owned companies, potentially subject to taxation.

6. Real Property Taxes:

  • Levied by municipalities at rates from 0.3% to 1.5% based on property market value.
  • Real estate transfer tax with progressive rates from 2% to 6%.

7. Inheritance Taxes:

  • State-based taxes with rates up to 8%.

8. V.A.T. and Other Taxes:

  • V.A.T. at federal, state, and municipal levels.
  • IPI (federal) averages a 20% rate. ICMS (state) ranges from 4% to 25%.

9. Corporate Income Tax:

  • Resident companies taxed at 15% on worldwide income, reaching an effective rate of about 34% with surtaxes and social contributions.
  • Dividends from resident entities aren't taxed, while those from foreign entities are considered taxable income.

10. Withholding Taxes for Corporations:

  • Dividends to non-residents are exempt from withholding tax.
  • Payments abroad on interests and royalties taxed at 15%, potentially increased to 25% for tax haven residents.
  • Withholding tax rates might reduce under tax treaties.

For deeper insights into Brazil's corporate legal framework, taxation, and tax treaties, the link provided offers more comprehensive information.

Remember, these details are informative but shouldn't replace advice tailored to individual circ*mstances. For personalized advice, consulting qualified attorneys and accountants specializing in Brazilian taxation is crucial.

Citizenship by investment in Brazil (2024)
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