International Taxation
Tax analysis of investments, income and transactions involving more than one jurisdiction.
Cross-border transactions require identifying tax residence, the source of income, the nature of payments and the relationship between the parties. Individuals and legal entities are subject to different regimes, as are direct investments, financial investments and controlled structures abroad. The analysis of tax treaties must consider their scope and conditions, without assuming that any international flow automatically benefits from a reduction or elimination of taxes. Reporting obligations are also part of the assessment.
The advisory work examines withholdings, tax credits and documentation for remittances and investments. In controlled transactions, transfer pricing rules require an analysis of the economic terms and specific supporting documentation. For individuals, investments, controlled entities and trusts abroad require attention to the relevant rules, including Law 14,754. The Brazilian analysis must be coordinated with a review of foreign legislation where necessary, distinguishing the effects in each country and the limits on the application of treaties.
Our work
- Analysis of cross-border income and investments
- Treaties, withholdings and tax credits
- Legal structuring and documentation of controlled transactions
Does having a company abroad eliminate tax obligations in Brazil?
No. Residence, control, income and the characteristics of the structure may give rise to taxation and reporting obligations in Brazil. The analysis differs for individuals and for legal entities.
Editorial review: