Brazil · Tax regime
Brazilian Worldwide Tax Regime
Reshaped by Lei 14.754/2023, which covers offshore assets, CFCs and trusts, and by Lei 15.270/2025, which brings in the IRPFM minimum tax from 2026. This is a tightening cycle. We list it here 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. Since 2024, it also 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
It attaches immediately on entry with a permanent visa. On a temporary visa, it attaches after 183 days in 12 months.
The facts
- Total landed cost
- This is not a programme with a fee. The cost is the tax.
- Route type
- Tax regime, not a visa
- 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
- a declaration of definitive entry, plus annual DIRPF filingannual reporting of foreign assets, and reporting to the Banco Central once you cross the CBE thresholdsrestructuring offshore holdings before arrival, to avoid the 15% CFC charge
- 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, whether distributed or not, for anyone holding over 50%. It applies equally to corporations, LLCs, partnerships and foreign trusts.
- Foreign trusts are transparent under this regime. Assets are treated as the settlor's during life, with fiscal transfer triggered on irrevocability, death or distribution, whichever comes first. Classic asset-protection trusts do not work here.
- Starting in 2026, the IRPFM minimum tax begins at 0% and rises in a straight line to 10% for annual income between BRL 600,000 and BRL 1.2 million. Above BRL 1.2 million, the rate holds at 10%.
- The offshore regularisation amnesty has closed. There is no reduced-penalty route left for historic undeclared assets.
- ITCMD inheritance tax is becoming progressive under the 2023 reform. Do not assume the old 8% ceiling still applies.
- There is no US–Brazil income tax treaty. That leaves US persons with an overlap that gets little relief.