Who this guide is for
This guide is for Brazilian companies owned by foreign groups that provide services to clients abroad, and for those that buy services from the parent or from other foreign companies.
Short answer. ISS is not levied on the export of services, but not every service for a foreign client is an export: a service developed in Brazil whose result is verified in Brazil does not qualify. PIS and Cofins are not levied on revenue from services provided to a person resident abroad when the payment represents an inflow of foreign currency. For services bought from abroad, ISS can apply and the Brazilian buyer can be the responsible party.
General information as of November 2026. It does not replace the analysis of each case.
Exporting a service
| Tax | Rule | Condition |
|---|---|---|
| ISS | It is not levied on the export of services to abroad (Complementary Law 116/2003, art. 2, I) | Services developed in Brazil whose result is verified here do not qualify, even when the payer lives abroad (sole paragraph) |
| PIS | It is not levied on revenue from services provided to a person resident or domiciled abroad (Law 10,637/2002, art. 5, II) | The payment represents an inflow of foreign currency |
| Cofins | Same rule (Law 10,833/2003, art. 6, II) | The payment represents an inflow of foreign currency |
| IBS and CBS (tax reform) | Exports of goods and services are immune (Complementary Law 214/2025, art. 8) | When these taxes apply |
The sole paragraph uses the place where the result is verified to exclude a service from the exemption. We check it for each service against the contract and the delivery.
Buying a service from abroad
ISS also applies to a service that comes from abroad or whose provision began abroad (Complementary Law 116/2003, art. 1, §1). The place of the tax is the buyer's establishment (art. 3, I), and the buyer of a service from abroad is the responsible party for the tax (art. 6, §2, I).
So a Brazilian company that pays its parent for services may owe ISS on that payment. The treatment of the charge between related parties is in our guide on intragroup services, and the other taxes on payments abroad are in the guide on sending money out of Brazil.
The invoice
From November 1, 2026, micro and small companies in the Simples Nacional must issue the NFS-e only through the National Issuer, whether or not the municipality has its own system, according to the portal's notice of October 29, 2026.
A company with a partner domiciled abroad cannot be in the Simples Nacional (Complementary Law 123/2006, art. 17, II), so that notice does not apply to it. For other taxpayers, we did not find a general obligation on the portal, and the system depends on the municipality. How an export is flagged on the invoice follows the layout of the system in use, and we set it up with it.
What we check before invoicing a foreign client
- Where the service is performed and where its result is verified.
- Who pays and in which currency. The rule refers to an inflow of foreign currency.
- The contract, so that it describes the service and the delivery.
- The municipality, which receives the ISS and sets the invoice rules.
- The proof of the inflow. It follows Revenue Service and Central Bank rules, which we check in each case.
How we work
We classify each service as an export or not, set up the invoice with the issuing system and keep the evidence of delivery and payment together with the accounting.
Legal basis and sources
- Complementary Law 116/2003, arts. 1, 2, 3 and 6.
- Law 10,637/2002, art. 5, II (PIS) and Law 10,833/2003, art. 6, II (Cofins).
- Complementary Law 214/2025, art. 8 (IBS and CBS).
- Complementary Law 123/2006, art. 17, II (Simples Nacional).
- National NFS-e portal: notice on the obligation for Simples Nacional taxpayers.
The Revenue Service rules on how the inflow of foreign currency is proven were not part of this review.