{"id":10030,"date":"2026-09-11T09:27:40","date_gmt":"2026-09-11T09:27:40","guid":{"rendered":"https:\/\/naventia.com\/imposto-sobre-lucros-no-exterior\/"},"modified":"2026-09-11T09:56:03","modified_gmt":"2026-09-11T09:56:03","slug":"imposto-sobre-lucros-no-exterior","status":"publish","type":"post","link":"https:\/\/naventia.com\/en\/imposto-sobre-lucros-no-exterior\/","title":{"rendered":"Tax on profits earned abroad: what the law says in 2026"},"content":{"rendered":"<\/p>\n<p>Brazil generally taxes the profits that Brazilian business owners and investors earn abroad. This is the point that most surprises business owners: the tax can be levied before the money even arrives in Brazil. The following sections show how to calculate, declare, take advantage of credits, and avoid penalties.<\/p>\n<hr>\n<blockquote>\n<p><strong>In summary:<\/strong><\/p>\n<ul>\n<li>Companies controlled abroad may generate tax obligations in Brazil on the balance sheet date, regardless of the repatriation of funds, increasing cash flow risk.<\/li>\n<li>The new 2024 law unified the 15% tax rate for profits of those who invest abroad, changing the calculation deadline to the end of the calendar year.<\/li>\n<li>The recognition of profits from subsidiaries through article 74 of Provisional Measure 2.158-35\/2001 requires special attention to currency conversion and the timing of availability to avoid penalties.<\/li>\n<li>Tax credits paid abroad operate with strict limits, preventing offsets that exceed the tax owed in Brazil, and are contingent upon formal documentation.<\/li>\n<li>The established case law of the Brazilian Supreme Court (STF) and the Superior Court of Justice (STJ) reinforces the taxation of profits from foreign subsidiaries, making accounting provisions and preventive planning essential for reducing tax risks.<\/li>\n<\/ul>\n<\/blockquote>\n<hr>\n<p>Naventia: Reduce tax risks in international expansion. Naventia connects Brazilian companies to the American market with strategic tax, legal, and operational planning tailored to each business.<a href=\"https:\/\/naventia.com\/en\/\" style=\"display:inline-flex;align-items:center;gap:9px;border-radius:10px;font-weight:700;font-size:15px;text-decoration:none;padding:13px 22px 13px 26px;background:#031B4E;color:#ffffff;\">Meet Naventia<svg width=\"17\" height=\"17\" viewbox=\"0 0 24 24\" fill=\"none\" stroke=\"#ffffff\" stroke-width=\"2.6\" stroke-linecap=\"round\" stroke-linejoin=\"round\" style=\"display:block;flex:0 0 auto;\"><path d=\"M5 12h14\"\/><path d=\"m12 5 7 7-7 7\"\/><\/svg><\/a><\/p>\n<h2 id=\"indice\" tabindex=\"-1\">Index<\/h2>\n<ul>\n<li><a href=\"#panorama-legal-e-normativo-o-que-rege-o-imposto-sobre-lucros-no-exterior\">Legal and regulatory overview: what governs the tax on profits earned abroad?<\/a><\/li>\n<li><a href=\"#quem-paga-pessoa-fisica-pessoa-juridica-e-os-regimes-que-se-aplicam\">Who pays: individuals, legal entities, and the applicable tax regimes.<\/a><\/li>\n<li><a href=\"#como-calcular-e-declarar-lucros-e-dividendos-do-exterior\">How to calculate and declare profits and dividends from abroad<\/a><\/li>\n<li><a href=\"#creditos-deducoes-e-como-evitar-a-dupla-tributacao\">Credits, deductions, and how to avoid double taxation.<\/a><\/li>\n<li><a href=\"#o-momento-da-tributacao-e-o-maior-risco-de-caixa\">The timing of taxation is the biggest cash flow risk.<\/a><\/li>\n<li><a href=\"#o-que-o-stf-e-o-stj-decidiram-sobre-lucros-de-controladas\">What the Supreme Federal Court (STF) and the Superior Court of Justice (STJ) decided regarding the profits of subsidiaries.<\/a><\/li>\n<li><a href=\"#checklist-de-conformidade-para-reduzir-risco-fiscal\">Compliance checklist to reduce tax risk.<\/a><\/li>\n<li><a href=\"#o-que-priorizar-diante-da-nova-realidade-tributaria\">What to prioritize in light of the new tax reality?<\/a><\/li>\n<li><a href=\"#diagnostico-fiscal-internacional-como-a-naventia-apoia-sua-empresa\">International tax diagnosis: how Naventia supports your company<\/a><\/li>\n<li><a href=\"#fontes\">Sources<\/a><\/li>\n<li><a href=\"#perguntas-frequentes\">Frequently Asked Questions<\/a><\/li>\n<\/ul>\n<h2 id=\"panorama-legal-e-normativo-o-que-rege-o-imposto-sobre-lucros-no-exterior\" tabindex=\"-1\">Legal and regulatory overview: what governs the tax on profits earned abroad?<\/h2>\n<p>The basis of the current system changed significantly from 2024 onwards, when it came into effect. <a href=\"https:\/\/presidencia.gov.br\/ccivil_03\/_ato2023-2026\/2023\/lei\/l14754.htm\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Law No. 14.754\/2023 (Planalto)<\/a>. This law reorganized the taxation of income and financial investments of individuals held outside of Brazil, unifying a large portion of these gains into a fixed tax rate of... <a href=\"https:\/\/normas.leg.br\/?urn=urn:lex:br:federal:lei:2023-12-12;14754!cap1\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">15%<\/a>, in addition to introducing specific rules for profits from subsidiaries and affiliates abroad.<\/p>\n<p>Prior to this, the provision that still governs the taxation of subsidiaries within the scope of legal entities is Article 74 of Provisional Measure No. 2,158-35\/2001. This article stipulates that profits earned by a foreign subsidiary or affiliate are considered available to the Brazilian parent company on the date of the balance sheet in which they were determined, not on the date the money actually enters the Brazilian company&#039;s cash flow. This mechanism generates a large part of the cash flow problems that we will discuss later.<\/p>\n<p>Two normative instructions complete this picture:<\/p>\n<ul>\n<li>A <strong>Normative Instruction RFB No. 2,180\/2024<\/strong> It details how to declare subsidiaries held abroad, the procedures for annual reporting, and the deadlines for reporting profits in the tax return.<\/li>\n<li>A <strong>Normative Instruction SRF No. 213\/2002<\/strong> It deals with the rules for consolidating the results of subsidiaries and affiliates, as well as currency conversion procedures and documentary requirements for tax credit purposes.<\/li>\n<\/ul>\n<p>The Brazilian Federal Revenue Service also publishes practical guidelines on how to fill out the tax return. According to the <a href=\"https:\/\/www.gov.br\/receitafederal\/pt-br\/assuntos\/meu-imposto-de-renda\/preenchimento\/manual-mir\/situacoes-especificas\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Gov<\/a>, Investments abroad must be listed in the &quot;Assets and Rights&quot; section, and the conversion to reais uses the closing dollar exchange rate on the last business day of December. This applies both to those who have an investment account in New York and to those who hold a stake in a holding company registered in Delaware.<\/p>\n<h2 id=\"quem-paga-pessoa-fisica-pessoa-juridica-e-os-regimes-que-se-aplicam\" tabindex=\"-1\">Who pays: individuals, legal entities, and the applicable tax regimes.<\/h2>\n<p>The answer to &quot;who is taxed&quot; depends on two factors: the type of taxpayer and the moment when the profit becomes taxable. Individuals and legal entities follow different logics, and confusing the two is one of the most costly mistakes we see in client diagnoses.<\/p>\n<p><strong>For individuals<\/strong>, Law No. 14,754\/2023 created the annual taxation regime: income from financial investments abroad is calculated on December 31 of each year, at a rate of 15%, and declared separately in the Annual Adjustment Declaration (DAA), without being mixed with the progressive income tax table on salaries. This changes the behavior of those who invest abroad: it is no longer possible to wait for the &quot;availability&quot; of profits to pay tax because the taxable event occurs at the end of the calendar year, regardless of redemption.<\/p>\n<p>There is also the taxation regime based on the date of availability, which applies to specific situations not covered by the annual assessment, such as certain income that only becomes taxable when actually paid, credited, or remitted to the beneficiary.<\/p>\n<p><strong>For legal entities<\/strong>, The scenario revolves around article 74 of Provisional Measure 2.158-35\/2001. Brazilian companies that control or hold a significant stake in companies abroad may have to recognize the profit of the foreign subsidiary in the results of the Brazilian parent company, subjecting this amount to Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL), generally under the actual profit regime. The distinction between subsidiary and affiliate is important here:<\/p>\n<ul>\n<li><strong>Controlled<\/strong>The Brazilian company holds, directly or indirectly, the power to decide on the financial and operational policies of the foreign company, usually by holding more than 50% of the voting capital.<\/li>\n<li><strong>Affiliated<\/strong>There is significant influence, but without effective control, generally with relevant participation that does not constitute a majority of votes.<\/li>\n<\/ul>\n<p>This difference alters the tax framework and the timing of profit recognition, therefore it must be expressly stated in the company&#039;s organizational chart, which any accountant consults before closing the balance sheet.<\/p>\n<h2 id=\"como-calcular-e-declarar-lucros-e-dividendos-do-exterior\" tabindex=\"-1\">How to calculate and declare profits and dividends from abroad<\/h2>\n<p>In practice, calculating tax on foreign profits involves three steps: converting values to Brazilian reais, calculating the tax due, and filling in the correct fields on the tax return. Here&#039;s a guide that usually avoids rework:<\/p>\n<ol>\n<li><strong>Convert using the closing price.<\/strong> According to <a href=\"https:\/\/www.gov.br\/receitafederal\/pt-br\/assuntos\/meu-imposto-de-renda\/preenchimento\/manual-mir\/situacoes-especificas\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Federal Revenue Service MIR Manual<\/a>, The value in foreign currency is converted to reais using the dollar purchase exchange rate set by the Central Bank on the last business day of December of the calendar year.<\/li>\n<li><strong>Identify the type of income.<\/strong> Dividends and profits from subsidiaries follow one logic; interest, rents, and gains from financial investments follow another, with a tax rate of 15% according to the rule consolidated since 2024 by <a href=\"https:\/\/valorinveste.globo.com\/imposto-de-renda\/noticia\/2026\/05\/21\/imposto-de-renda-2026-como-declarar-investimentos-no-exterior.ghtml\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Valor Investe<\/a>.<\/li>\n<li><strong>Fill out the &quot;Assets and Rights&quot; form.\u201c<\/strong> with the shareholding or the balance of the investment, and the specific form for &quot;Exempt and Non-Taxable Income&quot; or &quot;Income Subject to Exclusive\/Definitive Taxation&quot;, as applicable.<\/li>\n<li><strong>Use GCAP when there is a capital gain.<\/strong> The sale of real estate, stocks, or other assets abroad requires reporting using the Capital Gains Tax (GCAP) program, with tax payment due by the last business day of the month following the transaction.<\/li>\n<li><strong>Check the consistency between foreign balance sheets and Brazilian declarations.<\/strong> before transmitting, comparing values in the original currency with the converted values.<\/li>\n<\/ol>\n<p><strong>Pro tip:<\/strong> <em>Keep a spreadsheet with the date of each foreign balance sheet, the exchange rate used for conversion, and proof of withheld tax. This single habit resolves most discrepancies that lead to notifications from the tax authorities.<\/em><\/p>\n<p>A simplified example helps to visualize the calculation: an individual with financial investments abroad that generated the equivalent of R$ 100,000 in income during the year pays <a href=\"https:\/\/normas.leg.br\/?urn=urn:lex:br:federal:lei:2023-12-12;14754!cap1\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">15%<\/a> tax on that amount, i.e., R$ 15 thousand, calculated in the DAA and not in the monthly progressive tax table.<\/p>\n<p><img decoding=\"async\" src=\"https:\/\/naventia.com\/wp-content\/uploads\/2026\/09\/1789004004803_Como-calcular-e-declarar-lucros-e-dividendos-do-exterior-overview-diagram.jpeg\" alt=\"Como calcular e declarar lucros e dividendos do exterior \u2014 overview diagram\" title=\"\"><\/p>\n<h2 id=\"creditos-deducoes-e-como-evitar-a-dupla-tributacao\" tabindex=\"-1\">Credits, deductions, and how to avoid double taxation.<\/h2>\n<p>The tax paid abroad on the same profit does not, in theory, need to be paid twice. Brazilian legislation, including provisions of Law No. 14,754\/2023 itself, allows for the crediting of income tax paid abroad to offset the tax due in Brazil on the same income.<\/p>\n<p>This credit, however, has clear limits:<\/p>\n<ul>\n<li>The credited amount <strong>It can never exceed the Brazilian tax due.<\/strong> Regarding that same income; if the tax paid outside the tax period is higher, the surplus is simply not used in the current year.<\/li>\n<li>It is necessary <strong>documentary proof<\/strong> Regarding the tax paid: typically an official statement from the foreign tax authority, payment slip, or equivalent declaration, translated when required by the tax authorities.<\/li>\n<li><strong>For legal entities<\/strong>, The compensation follows a logic of deducting the Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL) due, within the limits established by the normative instructions applicable to subsidiaries and affiliates.<\/li>\n<li><strong>For individuals<\/strong>, The credit is applied directly against the 15% tax calculated in the DAA, respecting the same limit of not exceeding the amount due in Brazil.<\/li>\n<\/ul>\n<p>When a double taxation avoidance treaty exists between Brazil and the country where the profit was generated, the rules of the agreement may alter this calculation and define which country has priority in taxing a particular type of income. This does not mean automatic exemption in Brazil. As shown by the Supreme Federal Court&#039;s position on the taxation of subsidiaries abroad, the taxation of the Brazilian parent company on its own income can coexist with international conventions, because Brazil taxes the resident, not directly the foreign company. The treaty prevails only insofar as it resolves the conflict of jurisdiction between the two States; it does not eliminate the obligation to declare.<\/p>\n<h2 id=\"o-momento-da-tributacao-e-o-maior-risco-de-caixa\" tabindex=\"-1\">The timing of taxation is the biggest cash flow risk.<\/h2>\n<p>Article 74 of Provisional Measure 2.158-35\/2001 creates a liquidity trap that few business owners see before it&#039;s too late: the profit of the foreign subsidiary is considered available on the balance sheet date, not on the date the money actually enters the Brazilian company&#039;s account. This means that the parent company may have to pay corporate income tax (IRPJ) and social contribution on net profit (CSLL) on profits that are still held abroad, whether due to a reinvestment decision, contractual restriction, or simply because the board of directors decided not to distribute dividends that year.<\/p>\n<p>This mismatch between accounting and financial realities requires active currency planning. Companies that hold accumulated profits in foreign currency and do not provision for exchange rate fluctuations in reais risk closing their balance sheets with a tax liability greater than the cash available to pay it, especially in years of strong dollar appreciation.<\/p>\n<p>Common accounting errors that lead to penalties include:<\/p>\n<ul>\n<li>Discrepancy between the date of the foreign balance sheet and the date used for currency conversion in the Brazilian tax return.<\/li>\n<li>Lack of formal documentation of taxes paid abroad, which prevents the use of the credit.<\/li>\n<li>Failure to file the Declaration of Brazilian Capital Abroad (DCBE), required by the Central Bank of Brazil for those who hold assets above certain limits outside the country, results in a fine regardless of the tax situation.<\/li>\n<\/ul>\n<p>Analysts following the litigation point precisely to this. <a href=\"https:\/\/www.migalhas.com.br\/quentes\/463476\/stf-mendonca-leva-tributacao-de-lucros-no-exterior-ao-plenario-fisico\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Accounting discrepancies as one of the most frequent causes of tax audits.<\/a>, reinforcing that the problem is rarely the intention to evade taxes, but the lack of a routine for reconciling balance sheets.<\/p>\n<p><strong>Pro tip:<\/strong> <em>If your company holds retained earnings abroad for more than one fiscal year, provision the tax in reais as soon as the foreign balance sheet closes, not when you decide to repatriate. Waiting for repatriation to calculate the tax is the most common recipe for discovering, too late, that there is a lack of cash to pay the tax authorities.<\/em><\/p>\n<h2 id=\"o-que-o-stf-e-o-stj-decidiram-sobre-lucros-de-controladas\" tabindex=\"-1\">What the Supreme Federal Court (STF) and the Superior Court of Justice (STJ) decided regarding the profits of subsidiaries.<\/h2>\n<p>Case law has decisively changed the landscape for companies with subsidiaries or affiliates outside of Brazil. In 2026, the Brazilian Supreme Court formed a majority in favor of the constitutionality of taxing profits from subsidiaries abroad at the level of the Brazilian legal entity, understanding that the taxed income belongs to the parent company resident in the country, not directly to the foreign company.<\/p>\n<blockquote>\n<p>The ruling reached by the Brazilian Supreme Court in 2026 solidified the understanding that taxing the Brazilian parent company on profits earned by its foreign subsidiary does not violate the constitutional concept of income, because the taxable event is connected to the assets of the taxpayer residing in Brazil, and not to the fiscal sovereignty of the other country.<\/p>\n<\/blockquote>\n<p>This reading, described by <a href=\"https:\/\/oglobo.globo.com\/economia\/noticia\/2026\/08\/27\/stf-tem-maioria-a-favor-da-tributacao-de-lucros-de-controladas-no-exterior-por-empresas-brasileiras.ghtml\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">The Globe<\/a>, This reduces the scope for legally challenging the constitutionality of Article 74 of Provisional Measure 2.158-35\/2001. Companies that relied on this argument as a defense strategy need to reassess the risk of maintaining tax liabilities without provision.<\/p>\n<p>In the Superior Court of Justice, recent decisions follow the same line. The court upheld, in special appeals, the application of Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL) on profits of subsidiaries abroad based on article 74 itself, as shown. <a href=\"https:\/\/rotadajurisprudencia.com.br\/2026\/09\/stj-mantem-incidencia-de-irpj-e-csll-sobre-lucros-de-controlada-no-exterior\/\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Analyses of court decisions published by Rota da Jurisprud\u00eancia.<\/a>. This indicates convergence between the two superior courts, which reduces the chance of these rulings being reversed in the short term.<\/p>\n<p>In practice, this trend changes three things for those with an international corporate structure:<\/p>\n<ul>\n<li><strong>Accounting provisions are no longer optional.<\/strong> Companies that still treated the taxation of subsidiaries as a remote risk, subject to judicial reversal, need to recognize the liability more rigorously.<\/li>\n<li><strong>Pure litigation loses its effectiveness as an isolated strategy.<\/strong> It makes more sense to combine specific technical defenses (errors in investigation, deadlines, calculation basis) with preventive planning than to rely on a general argument of unconstitutionality.<\/li>\n<li><strong>The administrative route is gaining importance.<\/strong> Before resorting to litigation, evaluating administrative appeals and formal inquiries to the tax authorities is usually faster and less costly, reserving the judicial system for specific disagreements regarding calculations or the application of treaties.<\/li>\n<\/ul>\n<h2 id=\"checklist-de-conformidade-para-reduzir-risco-fiscal\" tabindex=\"-1\">Compliance checklist to reduce tax risk.<\/h2>\n<p>We have compiled the points that any business owner or accountant should review before the end of the fiscal year, especially those who have subsidiaries, affiliates, or significant financial investments abroad.<\/p>\n<ol>\n<li><strong>Map the entire corporate structure abroad.<\/strong>, precisely identifying what constitutes a controlled entity, an affiliate, or simply a minority stake, because this classification defines the applicable tax regime.<\/li>\n<li><strong>Reconcile the foreign balance sheet with the Brazilian financial statements.<\/strong> Every year, verifying if the reporting dates coincide with what the parent company is recognizing in its accounting.<\/li>\n<li><strong>Keep formal receipts for taxes paid abroad.<\/strong>, including payment slips and official statements, to support any loan application.<\/li>\n<li><strong>Review the currency conversion policy.<\/strong>, ensuring that all values use the correct closing rate on the date required by the tax authorities.<\/li>\n<li><strong>Confirm delivery of the DCBE to the Central Bank.<\/strong>, when the value of assets abroad exceeds the limits that generate this obligation.<\/li>\n<li><strong>Assess the existence of a treaty to avoid double taxation.<\/strong> Contact the country where the subsidiary or application is located, and document how it affects the tax credit.<\/li>\n<li><strong>Simulate the cash flow impact of taxation based on the balance sheet date.<\/strong>, before deciding to retain profits abroad over multiple fiscal years.<\/li>\n<\/ol>\n<p>This checklist reduces exposure to audits, but the most difficult part is usually the initial structuring: deciding where to open the company, how to design the holding company, and how to balance Brazilian and American taxation. This is where specialized consultancies step in to help Brazilian entrepreneurs who already have or are building operations in the United States, assisting in designing the corporate structure, communicating with the accountant responsible for tax calculations in Brazil, and organizing tax provisions before they become a cash flow problem.<\/p>\n<h2 id=\"o-que-priorizar-diante-da-nova-realidade-tributaria\" tabindex=\"-1\">What to prioritize in light of the new tax reality?<\/h2>\n<p>Taxation of profits abroad has ceased to be a matter of long-term planning and has become a short-term cash management problem. The most common mistake I see among Brazilian business owners with international operations is not ignorance of the law, but underestimating the speed at which liabilities grow between one balance sheet and the next.<\/p>\n<p>My practical recommendation has three layers. First, conduct a thorough assessment of accumulated tax liabilities before making any decisions regarding profit distribution, reviewing accounting policies with the same rigor you would apply to an external audit. Third, closely monitor the evolution of litigation in the Supreme Federal Court (STF) and the Superior Court of Justice (STJ): arguments that seemed solid three years ago have lost strength, and planning based on outdated case law is now a greater risk than it once was.<\/p>\n<blockquote>\n<p><em>\u2014 Flavio Inacarato<\/em><\/p>\n<\/blockquote>\n<h2 id=\"diagnostico-fiscal-internacional-como-a-naventia-apoia-sua-empresa\" tabindex=\"-1\">International tax diagnosis: how Naventia supports your company<\/h2>\n<p>If your company has subsidiaries, affiliates, or significant investments abroad, the risk isn&#039;t just paying taxes; it&#039;s paying them at the wrong time, without documented credit, or without provisioned cash flow. Naventia acts precisely at this turning point: instead of you trying to translate Brazilian laws, regulations, and Supreme Court decisions to the specific reality of your structure in the United States on your own, our team with a local presence already knows the terrain from both sides.<\/p>\n<p><a href=\"https:\/\/naventia.com\/en\/servicos\/\" target=\"_blank\" rel=\"noopener\"><img decoding=\"async\" src=\"https:\/\/naventia.com\/wp-content\/uploads\/2026\/09\/1788731760349_naventia.jpg\" alt=\"Naventia\" title=\"\"><\/a><\/p>\n<p>Consulting work can begin with a diagnosis of the company&#039;s current tax exposure, moving on to the most appropriate corporate structuring or reorganization, and continuing with ongoing support to ensure that tax calculations in Brazil and operations in the United States are aligned, avoiding unexpected liabilities. This reduces the risk of audits, avoids late provisioning, and provides cash flow predictability for those who decide to keep part of their profits reinvested abroad. Learn more <a href=\"https:\/\/naventia.com\/en\/servicos\/\" target=\"_blank\" rel=\"noopener\">Naventia&#039;s internationalization services<\/a> and schedule one <a href=\"https:\/\/naventia.com\/en\/contato\/\" target=\"_blank\" rel=\"noopener\">Initial diagnosis via the contact form.<\/a> to understand exactly where the risk lies in your current structure.<\/p>\n<h2 id=\"fontes\" tabindex=\"-1\">Sources<\/h2>\n<p>For those who want to verify each rule directly at the source, it&#039;s worth consulting:<\/p>\n<ul>\n<li><a href=\"https:\/\/presidencia.gov.br\/ccivil_03\/_ato2023-2026\/2023\/lei\/l14754.htm\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Law No. 14.754\/2023 (Planalto)<\/a><\/li>\n<li><a href=\"https:\/\/www.gov.br\/receitafederal\/pt-br\/assuntos\/meu-imposto-de-renda\/preenchimento\/manual-mir\/situacoes-especificas\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Gov<\/a><\/li>\n<li><a href=\"https:\/\/oglobo.globo.com\/economia\/noticia\/2026\/08\/27\/stf-tem-maioria-a-favor-da-tributacao-de-lucros-de-controladas-no-exterior-por-empresas-brasileiras.ghtml\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Brazil&#039;s Supreme Court holds majority in favor of taxing profits of subsidiaries held abroad \u2014 O Globo<\/a><\/li>\n<li><a href=\"https:\/\/valorinveste.globo.com\/imposto-de-renda\/noticia\/2026\/05\/21\/imposto-de-renda-2026-como-declarar-investimentos-no-exterior.ghtml\" rel=\"nofollow noopener noreferrer\" target=\"_blank\">Income Tax 2026: How to declare investments abroad \u2014 Valor Investe<\/a><\/li>\n<\/ul>\n<p>To better understand the risks of specific corporate structures, it is also helpful to read about... <a href=\"https:\/\/naventia.com\/en\/bitributacao-brasil-eua\/\" target=\"_blank\" rel=\"noopener\">double taxation between Brazil and the United States<\/a> and about <a href=\"https:\/\/naventia.com\/en\/tributacao-llc-eua-para-brasileiros\/\" target=\"_blank\" rel=\"noopener\">Taxation of LLCs for Brazilians<\/a>.<\/p>\n<p>This article provides general information and is not a substitute for the advice of a qualified financial advisor. Consult a qualified financial professional about your specific situation before acting on this information.<\/p>\n<h2 id=\"perguntas-frequentes\" tabindex=\"-1\">Frequently Asked Questions<\/h2>\n<h3 id=\"como-funciona-a-tributacao-de-lucros-no-exterior-no-brasil\" tabindex=\"-1\">How does taxation of foreign profits work in Brazil?<\/h3>\n<p>Legal entities with foreign subsidiaries may be subject to Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL) on the date of the subsidiary&#039;s balance sheet, according to article 74 of Provisional Measure 2.158-35\/2001, even without repatriation of funds.<\/p>\n<h3 id=\"como-o-ganho-de-capital-de-investimento-no-exterior-e-tributado-no-brasil\" tabindex=\"-1\">How is capital gain from foreign investment taxed in Brazil?<\/h3>\n<p>Capital gains from the sale of real estate, shares, or other assets abroad are calculated using the GCAP program, with tax due by the last business day of the month following the transaction, according to the progressive capital gains tax rates.<\/p>\n<h3 id=\"a-isencao-de-r-35-mil-no-exterior-ainda-e-valida\" tabindex=\"-1\">Is the R$35,000 exemption for foreign transactions still valid?<\/h3>\n<p>Each case must be assessed according to the specific type of income and the applicable legal provision.<\/p>\n<h2 id=\"recomendacoes\" tabindex=\"-1\">Recommendations<\/h2>\n<ul>\n<li><a href=\"https:\/\/naventia.com\/en\/tributacao-llc-eua-para-brasileiros\/\" target=\"_blank\" rel=\"noopener\">LLC Taxation in the US: Risks for Brazilians in 2026<\/a><\/li>\n<li><a href=\"https:\/\/naventia.com\/en\/bitributacao-brasil-eua\/\" target=\"_blank\" rel=\"noopener\">Brazil\u2013US Double Taxation: 4 Points About Your LLC<\/a><\/li>\n<li><a href=\"https:\/\/naventia.com\/en\/erros-tributarios-ao-abrir-empresa-nos-eua-o-que-estrangeiros-fazem-errado\/\" target=\"_blank\" rel=\"noopener\">Tax Mistakes When Opening a Company in the US: 8 Errors Foreigners Make<\/a><\/li>\n<li><a href=\"https:\/\/naventia.com\/en\/holding-patrimonial-internacional\/\" target=\"_blank\" rel=\"noopener\">International asset holding company: trust or foundation? 3 structures compared.<\/a><\/li>\n<\/ul>","protected":false},"excerpt":{"rendered":"<p>Understand how taxes on profits earned abroad will impact businesses in 2026: calculate taxes, use credits, and avoid penalties.<\/p>","protected":false},"author":6,"featured_media":10031,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-10030","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-expansao"],"_links":{"self":[{"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/posts\/10030","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/users\/6"}],"replies":[{"embeddable":true,"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/comments?post=10030"}],"version-history":[{"count":5,"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/posts\/10030\/revisions"}],"predecessor-version":[{"id":10038,"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/posts\/10030\/revisions\/10038"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/media\/10031"}],"wp:attachment":[{"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/media?parent=10030"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/categories?post=10030"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/naventia.com\/en\/wp-json\/wp\/v2\/tags?post=10030"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}