Definitive tax departure
Communication and Declaration of Definitive Departure from Brazil, reference date and effects on income and assets.
International tax restructuring
Leaving Brazil lawfully is a matter of sequence and timing.
Advisory on the change of tax residence for high-net-worth individuals and on the international relocation of wealth structures — covering definitive tax departure, double taxation treaties, CFC rules and reporting obligations.
Practice
Global. Clients across Brazil, North America, Europe, the Middle East and Asia.
Profile
Families and entrepreneurs with significant wealth and cross-border operations.
Method
Legal and tax diagnosis before any recommendation of jurisdiction or instrument.
Technical workstreams
What must be resolved before the move.
Timing of the move
Order between asset disposals, profit distribution and loss of tax residence — sequence changes the tax outcome.
Double taxation treaties
Analysis of Brazil's treaty network, residence tie-breaker rules and allocation of taxing rights.
Offshore holdings and vehicles
Assessment of corporate structures, funds and trusts, considering economic substance and tax transparency.
CFC rules and Law 14,754/23
Automatic taxation of profits of controlled foreign companies, offshores and trusts held by Brazilian residents.
Compliance and reporting
CRS, FATCA, Brazilian Central Bank reporting of foreign assets and destination-country obligations.
Method
From wealth diagnosis to a new tax residence.
01
Wealth map
Survey of assets, shareholdings, recurring income and current tax exposure.
02
Structure design
Destination jurisdiction, suitable vehicles and sequence of acts, with a projected tax burden.
03
Implementation
Corporate acts, tax departure, account opening and a calendar of ongoing filing obligations.
Frequently asked
What clients usually ask.
Yes, when there is an effective shift of the centre of vital interests and the departure obligations are met. What the law targets is simulated foreign residence.
Send us the details of your case.
The preliminary review is confidential and considers asset composition, jurisdictions involved and relocation horizon.