Short answer. When a Brazilian company pays a non-resident, the payment is usually subject to withholding income tax (IRRF) collected at source. The headline rate for most cross-border income is 15%, rising to 25% when the beneficiary sits in a low-tax jurisdiction — and a tax treaty can reduce or reallocate it. From 2026, dividends paid abroad are no longer exempt.
What triggers withholding
- Royalties and technical services. Generally 15% IRRF, frequently combined with CIDE at 10% on the remittance (and, depending on the payment, PIS/COFINS-Importação on services). [Source: RIR/2018 — Decreto 9.580/2018; Lei 10.168/2000 (CIDE) — Planalto]
- Interest on cross-border loans. Typically 15% IRRF (25% to tax havens), subject to treaty relief. [Source: RIR/2018 — Decreto 9.580/2018]
- Tax-haven beneficiaries. Payments to a jurisdiction with favorable taxation are generally taxed at 25%, under the list maintained by the tax authority. [Source: IN RFB 1.037/2010 — Receita Federal]
The collection mechanics of remittances abroad are set out in IN RFB 1.455/2014. [Source: IN RFB 1.455/2014 — Receita Federal]
The treaty layer
Brazil has a network of double-tax treaties that can cut the IRRF rate or assign taxing rights. Whether relief applies is analysed case by case, by jurisdiction and income type. Notably, because most treaties permit source withholding of up to 10–15%, the treaty network does not generally block Brazil’s new dividend withholding. [Source: Receita Federal — international tax treaties]
Dividends — new from 2026
These withholdings are reported monthly through EFD-Reinf (which replaced the annual DIRF from 2025). Historically, dividends paid abroad were not withheld. Under Lei 15.270/2025 (enacted 26 November 2025, effective 1 January 2026), a 10% IRRF applies to profits and dividends paid, credited or remitted to non-residents — regardless of amount, and without the R$50,000/month threshold available to residents. (For residents, the 10% applies to monthly distributions above R$50,000 by the same company; non-residents may instead claim an optional credit where the combined burden exceeds the nominal IRPJ+CSLL rates.) [Source: Lei 15.270/2025 — Planalto; Receita Federal guidance]
Practical takeaway
For a foreign parent, the true cost of extracting value from Brazil is the stack: entity-level IRPJ/CSLL, then withholding on the specific payment type — services, royalties, interest, and now dividends — measured against the relevant treaty. Map each payment flow to its rate and treaty position before structuring funding or repatriation.
FAQ
What is the general withholding rate on payments to non-residents? 15% for most income, 25% when the beneficiary is in a low-tax jurisdiction.
Are royalties and services withheld the same way? Royalties and technical services generally bear 15% IRRF plus 10% CIDE; the combination depends on the payment’s nature.
Are dividends paid abroad taxed? Yes, from 2026: 10% IRRF on dividends remitted to non-residents, regardless of amount, under Lei 15.270/2025.
📚 Part of our pillar guide: Corporate Tax in Brazil — The Complete Guide for Foreign Companies.
Sources
Official sources reviewed for this brief: the income-tax regulation (Decreto 9.580/2018 — RIR/2018), the CIDE law (Lei 10.168/2000), the 2026 dividend-taxation law (Lei 15.270/2025), and Receita Federal guidance on remittances abroad (IN RFB 1.455/2014) and the list of double-tax treaties.