Think offshore profits are untouchable?
Brazil’s 2026 CFC rules just changed everything.
Think offshore profits are untouchable?
Brazil’s 2026 CFC rules just changed everything.
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There is no minimum threshold—any net profit triggers CFC tax immediately.
If you spent more than 183 days in Brazil, you’re a tax resident. Your foreign company’s annual profit is taxed here automatically, even without withdrawals.
75%
Unpaid CFC taxes can result in fines up to 75% of the amount due, plus criminal prosecution.
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The law treats your foreign company’s net profit as if you earned it directly—every single year, distributed or not.
Dica
To comply, convert your foreign profits into BRL at the current exchange rate (R$ 6.20 = US$ 1) and report them on your annual tax return. Missing the deadline can trigger penalties.
Check if you control >50% of voting capital
Calculate annual net profit in BRL
File and pay 15% tax by the deadline
Protect your hard‑earned wealth from aggressive penalties. Let our experts guide you to full compliance.