International Tax Planning ยท 100% Online Service

Assets in more than one country should not mean paying tax twice.

For people who live, invest or run a business across Brazil and other countries. We put your Brazilian tax position in order, from tax residence to offshore structures, so you pay what is due, with no avoidable double taxation and no surprises in a tax audit. All handled remotely, from anywhere in the world.

  • Offshore companies, financial investments and trusts abroad, under the rules of Law 14,754/2023.
  • Exit from Brazilian tax residence, residency analysis and treaties to avoid double taxation.
  • International corporate structuring, foreign investment in Brazil and profit repatriation.
100% onlineVideo meetings, with no need to travel to Brazil.
Five languagesPortuguese, English, Spanish, Italian and German.
Electronic signatureEngagement letter and documents signed remotely.
In your time zoneScheduling that works for clients in Europe and the Americas.

When should you look into international tax planning?

You are moving out of Brazil

The move is planned or has already happened, but Brazil's Federal Revenue Service still treats you as a resident. Until your exit is formally declared, the income you earn abroad may still be taxed in Brazil.

You hold investments or a company abroad

A bank or brokerage account, an offshore company or a trust outside Brazil. The tax treatment of these structures changed in 2024, and tax that used to be deferred until redemption can now be charged every year.

You live abroad and still own assets in Brazil

A rental property, a stake in a company, investments or an inheritance on the way. Each type of income has its own withholding rules for non-residents, and selling real estate calls for careful handling of the capital gain.

Your company operates in more than one country

A subsidiary, a branch or shareholders abroad, with profits, interest, royalties and services flowing between companies in the same group. How these transactions are structured determines how much tax is paid, and where.

What has changed and where the risk lies

Where international tax planning usually goes wrong

Offshore companies no longer defer tax

Under Law 14,754/2023, profits of offshore investment companies controlled by Brazilian residents are now taxed every year, at 15%, even if they are not distributed. Structures set up under the old rules need to be reviewed.

Moving abroad does not change your tax residence by itself

If you leave without filing a formal exit, Brazil's Federal Revenue Service treats you as a resident for the first twelve months of your absence, taxing your worldwide income in Brazil.

Not every country has a treaty with Brazil

Brazil has treaties to avoid double taxation with Italy, Spain and Portugal, among others. The treaty with Germany ceased to apply in 2006, and there has never been one with the United States. In those cases, getting credit for tax paid abroad depends on reciprocity and on proof.

A structure without substance will not hold up

Tax authorities and courts look at the business purpose and the substance of a structure. Planning that exists only on paper is usually disregarded, with the tax charged plus interest and an aggravated penalty.

Our international tax planning services

Every case starts with a map: where you are tax resident, where your assets are, where your income comes from and which countries have the right to tax it.

Tax residence and exit from Brazil

Analysis of where you are tax resident, filing of the notice and the final return on leaving Brazil, and organization of your tax affairs when you move abroad or return to Brazil.

Offshore companies and investments abroad

Review and structuring of foreign companies under Law 14,754/2023, choice between the opaque and the transparent regime, and taxation of financial investments, funds and digital assets held outside Brazil.

Trusts and international estate planning

Tax treatment of trusts set up abroad, estate planning for assets spread across more than one country and coordination between Brazilian inheritance rules and those of the country where the assets are located.

Double tax treaties

Application of the treaties signed by Brazil, credit for tax paid abroad, and the proof of residence and certificates required to reduce withholding tax on dividends, interest and royalties.

Holding companies and international corporate structure

Design of the structure that will hold your shareholdings and investments, in Brazil or abroad, with attention to the substance required, the cost of maintaining it and the tax due when funds come in and go out.

Foreign investment in Brazil

Inflows of foreign capital registered with the Central Bank of Brazil, choice of tax regime for the Brazilian company, and planning for returns on the investment and repatriation of capital.

Dividends, interest and payments abroad

Planning for profit distributions, interest on net equity, royalties and payments for services abroad, including the withholding tax on dividends sent out of Brazil that took effect in 2026.

Transfer pricing

Alignment of transactions between group companies with Brazil's transfer pricing rules, which have followed OECD guidelines since 2024, with documentation to support the prices charged.

Reporting, voluntary disclosure and tax disputes

Reporting of foreign assets and income to the Federal Revenue Service and the Central Bank of Brazil, regularization of undeclared assets, and defense in audits and tax assessments involving international transactions.

Who handles your case

Tax partners who speak the language of your business

Jonathan Doering Darcie

Jonathan Doering Darcie

Partner | Brazilian Bar OAB/RS 68,892

Jonathan Doering Darcie is a partner at Doering & Darcie, practicing tax, corporate and business law, and leads the structuring of assets and transactions that span more than one country.

He holds a doctorate and a master's degree in law from the Federal University of Rio Grande do Sul and is a guest lecturer in undergraduate and graduate programs. He works in Portuguese, English, German and Spanish.

Leonardo Barcelos de Oliveira

Leonardo Barcelos de Oliveira

Partner | Brazilian Bar OAB/RS 76,205

Leonardo Barcelos de Oliveira is a partner at Doering & Darcie, practicing tax and business law, with a focus on tax planning and on defending individuals and companies before the tax authorities.

He holds a master's degree in business law from Unisinos and a specialization in tax law from IBET, the Brazilian Institute of Tax Law. He works in Portuguese, Spanish, English and Italian.

How our 100% online service works

First contact

You reach the firm by WhatsApp or email, from any country, and describe your situation: where you live, where your assets are and what you plan to do. We work in Portuguese, English, Spanish, Italian or German.

Assessment

We map your tax residence, assets, sources of income and the countries involved, and show you where you are overpaying, where you risk an assessment and which obligations are still open.

Video meeting

The partner in charge presents the strategy, costs, timelines and possible scenarios, at a time that suits your time zone.

Proposal and engagement

Scope and fees are set out in writing before any work begins, and the engagement letter is signed electronically, with no need to come to Brazil.

Implementation and ongoing support

Filings, notices, structures and registrations are all handled remotely, under a power of attorney when someone needs to act in Brazil, and in direct contact with your accountant or advisor abroad.

Frequently Asked Questions

Is the service really 100% online?
Yes. Meetings take place by video call, documents are exchanged digitally and the engagement letter is signed electronically. You never need to travel to Brazil. When a step requires someone to be physically present here, such as a notary registration or representation before a government agency, it is done under a power of attorney. We work with clients living in any country, in Portuguese, English, Spanish, Italian and German.
Is it legal to have an offshore company or a bank account abroad?
Yes, as long as everything is declared. Foreign assets and income must be reported on your Brazilian income tax return, and anyone holding US$1 million or more in assets abroad must also file the Brazilian Capital Abroad report with the Central Bank. Holding assets outside Brazil is not the problem; failing to report them, or taxing them incorrectly, is.
How are offshore companies taxed since Law 14,754/2023?
Since 2024, profits of foreign companies controlled by an individual resident in Brazil are taxed every year at 15%, based on the December 31 balance sheet and even if nothing is distributed, when the company's income is mainly passive or it is located in a low-tax jurisdiction. There is an option for the transparent regime, under which the company's assets and income are treated as if the individual held them directly. Financial investments held directly abroad are now also taxed at 15% on the annual return. Which route makes sense depends on the type of asset, the income it generates and what you plan to do with it.
I am moving abroad. Do I need to file a formal exit from Brazil?
As a rule, yes. The exit notice and the final exit return set the date on which you stop being a resident for Brazil's Federal Revenue Service. From then on you are taxed in Brazil only on Brazilian-source income, usually through withholding. Without this step, you remain a resident for the first twelve months of your absence and may be taxed on the income you earn abroad. You will usually also need to appoint an attorney-in-fact in Brazil and update your status with banks and brokers.
Does Brazil have a double tax treaty with the country where I live?
It depends on the country. Brazil has treaties in force with more than thirty countries, including Italy, Spain, Portugal, France, Belgium, the Netherlands and Austria. The treaty with Germany ceased to apply in 2006 and has not been replaced, and there has never been a comprehensive income tax treaty with the United States. Even without a treaty, tax paid abroad can in some cases be credited in Brazil on the basis of reciprocity. Each situation calls for checking the rule for that country and that type of income.
I live abroad and own property or investments in Brazil. How am I taxed?
As a non-resident, you are taxed in Brazil on Brazilian-source income, generally through withholding. Rent is subject to 15% withholding, and the sale of real estate triggers tax on the capital gain, paid through your attorney-in-fact. Financial investments made under the special regime for non-resident investors may receive more favorable treatment. When the beneficiary lives in a low-tax jurisdiction, rates go up, generally to 25%.
Is international tax planning the same as hiding assets?
No, and we do not do that. Tax planning means choosing, among the options the law allows, the one with the lowest tax burden for your situation, with everything declared. Structures without a business purpose or without substance are usually disregarded by the tax authorities, with tax, interest and penalties charged. That is why we tell you plainly when a structure is not worth it, whether because of the cost of maintaining it or the risk.
Do you work with my accountant or advisor abroad?
Yes, and we recommend it. The Brazilian side of your planning has to fit with the rules of the country where you live or where your assets are. We coordinate directly with your accountant, lawyer or wealth manager abroad, so that the returns filed in both countries tell the same story.
Doering & Darcie

Doering & Darcie

A modern practice built on four decades of tradition.

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