14 articles
Brazil's thin-cap rules cap how much interest on foreign related-party debt is deductible — 2:1 for related parties, 0.3:1 for tax havens. How they work alongside transfer pricing.
Does Brazil's QDMTT apply to your group? Learn the Additional CSLL scope, 2026 payment, DCTFWeb reporting and compliance steps.
CIDE is a 10% Brazilian contribution on royalties, technical services and tech transfer paid abroad. Who bears it, its broad 2025 scope, and how it stacks with IRRF.
How Brazil's municipal ISS tax applies to services, imports and exports, and why cross-border contracts need careful tax wording.
From 2026 Brazil taxes dividends: a 10% withholding on all dividends remitted abroad, no threshold. What foreign shareholders pay and the relief mechanism.
A guide to corporate tax in Brazil for foreign companies: IRPJ, CSLL, the ~34% rate, profit regimes, transfer pricing, 2026 dividend tax and withholding.
How Brazil's double-tax-treaty network cuts tax on cross-border payments — and the notable gap: no in-force treaty with the United States (reciprocity instead).
How Juros sobre Capital Próprio (JCP) lets a Brazilian company deduct shareholder returns: the 17.5% withholding from 2026, Lucro Real and the dividend tax.
How Brazil's two profit regimes — Lucro Real and Lucro Presumido — change the IRPJ/CSLL a foreign-owned subsidiary pays, and when each is available.
How Brazil taxes software and SaaS — the STF ruling it's a service (ISS, not ICMS), the tax on cross-border payments, and what the 2026 reform changes.
Brazil replaced its transfer-pricing system with arm's-length, OECD-aligned rules (Lei 14.596/2023), mandatory from 2024. What changed and what you must document.
How Brazil's IRRF taxes cross-border payments — services, royalties, interest and, from 2026, dividends — the 15%/25% rates, and the role of tax treaties.
How IRPJ and CSLL tax a Brazilian subsidiary's profit, which profit regime to choose, and what changes for foreign owners — including the 2026 dividend tax.
A sales rep, a warehouse, a server — what actually creates a taxable presence under Brazilian rules and treaties.