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Foreign companies · Taxes

Brazil's tax treaties: what changes for those who invest in the country

How agreements between countries can affect the taxes on the money you receive from Brazil, which countries appear on the official list and what to check before investing.

Updated October 2026Technical review: Wanderson Pires Almeida · CRC SP 280216/O-0

Who this guide is for

This guide is for foreign individuals and companies that plan to open a company in Brazil, buy a stake in a Brazilian business or expand an existing operation.

If you are assessing an investment, one of the questions is: after taxes, how much of the result can I receive in my own country?

The answer depends on the taxation of the Brazilian company, on the type of payment sent abroad and on the rules of the country where you or your company are tax resident. A tax treaty can influence this calculation.

Tax residence is the country in which a person or company is considered resident for tax purposes. It can be different from the investor's nationality or from the country where the funds come from.

Short answer. Brazil has agreements with several countries to avoid double taxation of income. They can set limits on certain taxes and provide mechanisms to relieve the charge on the same income in two countries.

Having an agreement, however, does not mean receiving money from Brazil without paying taxes. You need to check the country of residence of the recipient, the nature of the payment and the conditions of the treaty.

The Receita Federal's list also includes historical records, such as the agreement with Germany, without effect since 2006. So finding a country's name on the page is not enough to conclude that a benefit applies. See the official page of the Receita Federal.

General information as of October 2026. Confirm your case with your advisors.

What a tax treaty does

A tax treaty, also called an agreement or convention to avoid double taxation, sets how two countries must treat certain income.

For someone who invests in Brazil, it can have three main effects:

  • Limit certain taxes on the way out. Some articles set a ceiling for the tax charged by the country the payment comes from.
  • Provide ways to relieve double taxation. The recipient's country can grant a credit or apply another mechanism set in the agreement.
  • Define how to classify the income. Dividends, interest, royalties and services can receive different treatment.

Withholding tax is the tax deducted by the payer before transferring the amount to the beneficiary. When it applies, the Brazilian company pays this tax and sends the balance abroad.

The treaty must be read together with the applicable legislation. A limit set in the agreement does not mean that it will necessarily be the rate charged: the domestic rule may set a lower taxation.

What this changes in the return on the investment

To assess how much you can receive, it helps to separate three stages:

StageWhat to check
The Brazilian company makes a profitWhich taxes apply to the operation and how much profit is available for distribution.
The amount is paid to the foreign investorWhether there is withholding in Brazil and whether the treaty affects this payment.
The investor receives abroadWhether there is taxation in the country of residence and whether the tax paid in Brazil can be used.

The Brazilian company's tax and the tax on the payment to the partner are different charges. Do not assume that all the taxes paid by the company can be deducted by the investor abroad.

It also makes a difference whether you invest directly as an individual or through a foreign company. Some benefits depend on the profile of the beneficiary, on the shareholding and on other conditions set in the agreement.

A simple example

Suppose a Brazilian company has R$ 100,000 of profit available to distribute to its partner abroad, after the company's own taxes.

If the payment is subject to a 10% withholding, with no exception or different treatment that applies, R$ 10,000 will be paid in Brazil and R$ 90,000 will go to the beneficiary.

This is not necessarily the investor's final net result. You need to check whether the country where the investor lives also taxes this receipt and whether it allows the tax paid in Brazil to be used.

Since January 2026, Brazilian law sets a 10% withholding on profits and dividends sent abroad, subject to exceptions and transition rules (Law 15,270/2025). Applying it to your case also requires checking any treaty.

Treaty and reciprocity: what is the difference?

These concepts appear together in searches about international taxation, but they have different functions.

SituationWhat it means for the analysis
An applicable treaty existsIts articles, protocols and conditions must be examined for the payment you intend to make.
Reciprocity is recognisedThere is recognition of reciprocal treatment for certain tax compensations; this does not replace a treaty.
No applicable treaty was identifiedThe Brazilian taxation must be analysed under the domestic rules, and the treatment abroad depends on that country's rules.

The Receita Federal recognises reciprocity with Germany, the United States and the United Kingdom regarding the compensation of tax, within the applicable limits. This guidance deals with the use, in Brazil, of tax paid abroad. It does not, by itself, reduce the withholding on payments sent by a Brazilian company (see the Receita Federal questions and answers on individual income tax).

The absence of prior recognition does not, on its own, allow the conclusion that no reciprocity can be proven. The Receita provides for situations in which the taxpayer must present that proof (see the 2026 questions and answers).

The countries listed in the guide

The list below reproduces the 39 countries on the Receita Federal list, published on June 12, 2026 and updated on August 28, 2026. It is a starting point to locate the agreement, not a confirmation of a benefit or of immediate application.

For each operation, consult the official text and its dates of entry into force and of effect.

CountryMain reference in Brazil
South AfricaDecree 5,922/2006
GermanyAgreement without effect since January 1, 2006
ArgentinaDecree 87,976/1982
AustriaDecree 78,107/1976
BelgiumDecree 72,542/1973
CanadaDecree 92,318/1986
ChileDecree 4,852/2003
ChinaDecree 762/1993
South KoreaDecree 354/1991
DenmarkDecree 75,106/1974
United Arab EmiratesDecree 10,705/2021
EcuadorDecree 95,717/1988
SlovakiaDecree 43/1991
SpainDecree 76,975/1976
PhilippinesDecree 241/1991
FinlandDecree 2,465/1998
FranceDecree 70,506/1972
HungaryDecree 53/1991
IndiaDecree 510/1992
IsraelDecree 5,576/2005
ItalyDecree 85,985/1981
JapanDecree 61,899/1967
LuxembourgDecree 85,051/1980
MexicoDecree 6,000/2006
NorwayDecree 86,710/1981
NetherlandsDecree 355/1991
PeruDecree 7,020/2009
PolandDecree 12,865/2026
PortugalDecree 4,012/2001
Czech RepublicDecree 43/1991
RussiaDecree 9,115/2017
SingaporeDecree 11,109/2022
SwedenDecree 77,053/1976
SwitzerlandDecree 10,714/2021
Trinidad and TobagoDecree 8,335/2014
TurkeyDecree 8,140/2013
UkraineDecree 5,799/2006
UruguayDecree 11,747/2023
VenezuelaDecree 8,336/2014

The main reference does not necessarily include all later amendments. The official page of the Receita Federal gathers the instruments and related acts.

Cases that deserve attention

Germany

The name appears on the official list for historical reasons. The agreement stopped producing effects from January 1, 2006.

A German investor should not calculate the return using the benefits of that old text. The reciprocity recognised by Brazil has another purpose and does not restore the treaty.

Slovakia and the Czech Republic

Both appear under the same Decree 43/1991, which comes from the former Czechoslovakia.

United States

This guide's survey does not identify a comprehensive income tax treaty in force between Brazil and the United States.

For an American individual or company, the analysis must separate the taxes charged in Brazil from the American rules on the receipt and any credit. Brazilian reciprocity does not automatically resolve the taxation in the United States.

United Kingdom

Brazil and the United Kingdom signed a treaty on November 29, 2022. It does not appear on the Receita Federal list updated on August 28, 2026. The signature of an agreement does not mean that it can already be used for any payment.

Before applying a benefit, confirm that the required procedures have been completed and the date from which each provision produces effects. The relevant date can vary by tax and by period.

Ireland and Australia

These countries do not appear on the list used in this guide. This means the Brazilian taxation must be analysed under the domestic rules and that you need to check, in the investor's country, how the income received will be treated.

The absence of a treaty does not prevent investing in Brazil, and it does not mean, automatically, that every tax will be charged twice.

Agreements amended by protocols

A protocol is an instrument that modifies or complements the original agreement.

Consulting only the first decree can lead to an outdated conclusion. The list shows protocols promulgated in 2025 and 2026 for Chile, China, India, Norway, Singapore and Sweden, and a new agreement with Poland, promulgated by Decree 12,865/2026. The analysis must consider the later amendments, their dates of application and the relevant interpretative acts.

Do dividends, services and licences get the same treatment?

No. The real purpose of the payment is essential.

Dividends reward the partner's share in the profits. Interest rewards a debt. Royalties can reward certain rights of use. Services correspond to activities actually performed.

A foreign company can receive more than one of these payments, but each needs its own basis, documentation and tax treatment.

It is not enough to change the name of the transfer to obtain a different taxation. Nor should the alternative be chosen by looking only at the tax withheld: there can be other taxes, obligations and effects on the Brazilian company's result.

Our guide on sending money out of Brazil compares these forms of payment. The remittance calculator helps you test the amounts and the assumptions of the operation.

What information do we need to assess your case?

You do not need to know Brazilian legislation before talking to us. To start, we need to understand:

  • In which country you or the investing company are tax resident.
  • Whether the investment will be made by an individual or by a company.
  • What stake will be acquired in the Brazilian company.
  • What activity will be carried out in Brazil.
  • Which payments are planned: profits, interest, services, licences or others.
  • Whether the investment is being planned or already exists.

Depending on the operation, tax residence documents, contracts, corporate information and accounting records may also be needed.

This documentation lets us check the conditions of the treaty and support the treatment adopted. The exact list depends on the structure and on the payment.

How to confirm your country's status

The check should follow four steps:

  1. Locate the country on the Receita Federal page. Identify the agreement, its amendments and the published notes.
  2. Confirm the entry into force and the dates of application. An agreement that is signed or published can have rules that start to produce effects later.
  3. Read the article that matches the payment. The treatment of dividends can be different from that of interest or services.
  4. Check the treatment in the recipient's country. The calculation of the return must consider both sides of the operation.

The Foreign Ministry's Concórdia database and the texts published on the Planalto website complement this check.

Rules and guidance used in this guide, checked in October 2026:

  • Receita Federal: agreements to avoid double taxation and prevent tax evasion, list published on June 12, 2026 and updated on August 28, 2026.
  • The promulgation decree of each agreement, as shown in the table, and the decrees of the 2025 and 2026 protocols.
  • Law 15,270/2025: 10% withholding on profits and dividends sent abroad, since January 2026.
  • Acts of reciprocity of the Receita Federal: AD SRF 28/2000 (United States), AD SRF 48/2000 (United Kingdom) and ADI SRF 16/2005 (Germany).
  • Receita Federal questions and answers on individual income tax: 2024 and 2026.
  • Foreign Ministry's Concórdia database, for the status of each agreement.

How we work

Move Advisory is the consulting area of Move Online, an accounting firm in São Paulo founded in 2017.

We support foreign investors and companies in assessing the Brazilian structure, comparing the forms of payment abroad and organising the local accounting and tax obligations.

In the diagnosis, we identify the investor's country, the nature of the payments and the points of the treaty that need to be examined. We compare the scenarios with the numbers of the operation and indicate the documents needed.

Taxation in the investor's country of residence must be confirmed with your local advisors. This coordination helps to assess the return considering the whole operation. See the services page.

Frequently asked questions

Does having a treaty mean not paying tax?

No. The agreement can limit certain charges or provide mechanisms to relieve double taxation. The result depends on the payment and on the applicable conditions.

Can I invest in Brazil if my country has no treaty?

Yes. The existence of a treaty is one element of the tax analysis, not a general condition to open or acquire a stake in a Brazilian company.

Does the treaty apply to individuals and companies?

It can cover both, but you need to check who is covered and which conditions apply to each income. The treatment can vary by beneficiary.

Does the tax paid by the Brazilian company become a credit for the partner?

Not automatically. You need to distinguish the company's taxes from the tax on the payment to the investor and check the rules of the country where the investor lives.

Can I use a company in another country to obtain a benefit?

The analysis requires checking the real structure, the tax residence, the conditions of the treaty and the rules against abusive use. Opening a company in a given country does not, by itself, guarantee the benefit.

Does the calculator confirm that I am entitled to the treaty rate?

No. It estimates results from the information and rates used. The right to the treatment must be confirmed before making the payment.

Responsible for this guide

Founding partner and technical review: Wanderson Pires Almeida · CRC SP 280216/O-0

Understand the effect of the treaty on your investment

Tell us your country of tax residence, how you plan to invest and what amounts you expect to receive from Brazil. We assess the Brazilian taxation, the points to confirm abroad and the documents needed for the next steps.

Planning to operate in Brazil? We take care of the Brazilian side.

atendimento@moveonline.com.br