

International Tax Planning ยท 100% Online Service
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.
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.
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.
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.
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
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 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

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.

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