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Foreign loans into Brazil: SCE-Crédito reporting, IOF by term, prepayment and intercompany funding

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Last verified: 2026-10-27 · Status: Changing

A Brazilian company may borrow abroad freely, in any currency, from its parent or a bank, at terms compatible with international markets. Loans of US$1,000,000 or more must be declared in the Central Bank's SCE-Crédito before the money arrives, with the payment schedule within 30 days, or repayments can be blocked. IOF is zero on loans with an average term over 364 days and 3.5 percent on shorter ones, and early repayment of a long loan can trigger the 3.5 percent retroactively.

USD figures use the Banco Central do Brasil PTAX selling rate of R$5.5007 per US dollar for 26 October 2026, the last rate published before verification. Conversions are for orientation only; the rate on the day of each FX contract will differ.

Key facts

External loan amount that triggers SCE-Crédito reporting	1000000 USDResolução BCB nº 278 art. 23 I, as of 2026-10-27 · in force
Financed import over 180 days that triggers SCE-Crédito reporting	500000 USDResolução BCB nº 278 art. 23 II, as of 2026-10-27 · in force
Deadline to declare the loan payment schedule	30 daysResolução BCB nº 278 art. 29, as of 2026-10-27 · in force
Prior approval for foreign loans	No, free with reporting Resolução BCB nº 278 art. 5, as of 2026-10-27 · in force
IOF on inflow of registered foreign loans with average term up to 364 days	3.5 %Decreto nº 6.306 art. 15-B XII, as of 2026-10-27 · in force
IOF on inflow and outflow of foreign loans with average term over 364 days	0 %Decreto nº 6.306 art. 15-B XI, as of 2026-10-27 · in force
Minimum average term for zero IOF on foreign loans, more than	364 daysDecreto nº 6.306 art. 15-B XI and XII, as of 2026-10-27 · in force
Banco Central do Brasil PTAX selling rate, reais per US dollar	5.5007 BRLBanco Central do Brasil PTAX, as of 2026-10-26 · in force

The rule

1. Contracting and renegotiating external credit is free in any currency. Costs and other conditions must be compatible with international markets and clearly set in the contract. Payments are limited to what is needed to settle principal, interest and charges. Early repayment, including of charges, and prepaid interest are allowed.Resolução BCB nº 278, art. 7 as worded by Resolução BCB nº 575 of 18 June 2026, Arts. 5, 6, 7 and 8, 2022-12-31 official text · verified 2026-10-27 · changed: From 1 October 2026 art. 7 limits all payments, not only FX remittances, to principal, interest and charges, because loans may now be paid from foreign currency accounts in Brazil.

2. External credit includes direct loans, international bond issues, privately placed bonds in Brazil, financing, financed imports, export prepayments and external financial leases, even when the money stays abroad.Resolução BCB nº 278, Art. 2 I, 2022-12-31 official text · verified 2026-10-27

3. SCE-Crédito reporting is required for direct loans, financing (including from international organizations) and bonds of US$1,000,000 or more; financed imports with payment term over 180 days of US$500,000 or more; and export prepayments and external financial leases with payment term over 360 days of US$1,000,000 or more. Non resident parties must first be registered in the CDNR.
Example: A US$2,000,000 intercompany loan (R$11,001,400) must be declared; a US$800,000 loan (R$4,400,560) need not be. / Threshold US$1,000,000 for loans and bonds.Resolução BCB nº 278, art. 23 as worded by Resoluções BCB nº 492/2025 and 575/2026, Arts. 23 and 24, 2026-06-18 official text · verified 2026-10-27

4. The terms and payment conditions must be declared before the money enters Brazil when it comes in through an FX contract or a non resident reais account, and within 30 days of disbursement in other cases. The payment schedule, needed for any payment, must be declared within 30 days of the inflow, customs clearance, service or disbursement abroad.Resolução BCB nº 278, arts. 28 and 29 as worded by Resoluções BCB nº 348/2023 and 575/2026, Arts. 28 and 29, 2026-06-18 official text · verified 2026-10-27

5. A new declaration is required within 30 days after any change of maturity, renegotiation of financial terms or change of debtor (except reorganization, succession or court order). Conversions of interest into principal, or between loans and equity, must also be reported within 30 days.Resolução BCB nº 278, art. 25-A as worded by Resolução BCB nº 492/2025, Arts. 25 and 25-A, 2025-08-14 official text · verified 2026-10-27

6. IOF on FX for external loans: zero on inflow and outflow, except registered loans with a minimum average term of up to 364 days, whose inflow bears 3.5 percent. If a loan is repaid early, in whole or in part, before the minimum average term, the 3.5 percent becomes due with late interest and a fine.
Cost to do it: 3.5 percent of principal on short loans; zero on loans over 364 days held to term.
Example: Six month loan of US$2,000,000: IOF of about R$385,049. / US$70,000 of IOF on the six month loan; zero on a two year loan.Decreto nº 6.306, art. 15-B as worded by Decreto nº 12.499 of 11 June 2025, Art. 15-B, items XI and XII, §§ 1 to 3, 2025-06-11 official text · verified 2026-10-27 · changed: Decreto nº 12.499 of 11 June 2025 set item XII at 3.5 percent for loans of up to 364 days (it had been 6 percent for up to 180 days). Its validity was restored by an STF injunction in ADC 96 on 16 July 2025, issued ad referendum of the full court.

7. Export prepayments may be made by the importer, a non financial company abroad or a foreign financial institution and are repaid through shipments or services; if the export does not happen, the money may be returned abroad or converted into direct investment or a direct loan. External financial leases must run no longer than the asset's useful life and include a purchase or renewal option; in a sale and leaseback the contract must be below 90 percent of the asset's cost.Resolução BCB nº 278, Arts. 12, 13 and 14, 2022-12-31 official text · verified 2026-10-27

8. Unreported or irregular loans can be barred from related transfers, including repayments, until fixed, besides penalties. Supporting documents are kept for ten years after the loan ends.Resolução BCB nº 278, Arts. 4, 18 and 22, 2022-12-31 official text · verified 2026-10-27

Operation	Term	Threshold
Direct loan, financing, international or private bond	Any	US$1,000,000 or more
Financed import of goods or services	Over 180 days	US$500,000 or more
Export prepayment	Over 360 days	US$1,000,000 or more
External financial lease	Over 360 days	US$1,000,000 or more

Which foreign credit must go into SCE-Crédito (Resolução BCB nº 278 art. 23).

Average term	IOF on inflow	Amount
Up to 364 days	3.5 percent	US$70,000 (R$385,049)
Over 364 days, held to term	Zero	Zero
Over 364 days, repaid before the minimum average term	3.5 percent plus late interest and fine	US$70,000 plus charges

IOF on a US$2,000,000 intercompany loan (Decreto nº 6.306 art. 15-B).

Worked example

A foreign parent lends its Brazilian subsidiary US$2,000,000 (R$11,001,400) for three years. Before disbursement the subsidiary declares the terms in SCE-Crédito; within 30 days of the inflow it declares the schedule (Resolução BCB nº 278 arts. 28 and 29). IOF on the inflow is zero (Decreto nº 6.306 art. 15-B XI). If the subsidiary repays it after eight months, the average term falls below 365 days and IOF of 3.5 percent, US$70,000 (R$385,049), becomes due with late interest and a fine (art. 15-B § 2). Interest paid to the parent also bears withholding income tax (see Withholding on remittances) and must respect thin capitalization limits (see Thin capitalization).

Step by step

1. Register the foreign lender in the CDNR (Resolução BCB nº 278 art. 24).
2. Set an interest rate and terms you can show are compatible with international markets (art. 6), and check transfer pricing and thin capitalization.
3. Choose an average term over 364 days if you want zero IOF and do not plan to prepay early (Decreto nº 6.306 art. 15-B XI and § 2).
4. Declare the operation in SCE-Crédito before the inflow and the schedule within 30 days (arts. 28 and 29).
5. Report any change of maturity, terms or debtor, and any capitalization of interest or conversion into equity, within 30 days (arts. 25 and 25-A).
6. From 1 October 2026, consider receiving and repaying the loan through a foreign currency account in Brazil (see Foreign currency accounts).

Common traps

Prepaying a long loan. Repaying before the minimum average term triggers the 3.5 percent IOF retroactively with interest and a fine (Decreto nº 6.306 art. 15-B § 2).
Declaring late. Terms must be in SCE-Crédito before an FX inflow; without the schedule, repayments cannot be processed (Resolução BCB nº 278 arts. 28 and 29).
Paying more than principal, interest and charges, such as fees not in the contract. Payments are limited to those amounts (art. 7).
Converting a loan into capital informally. Conversions between loans and equity must be reported within 30 days (art. 25-A).

Sources

Related: Brazil country profile · live dashboard · central bank and release calendar · our posts on X · where Argentina is involved, see The Argentine Thread guide

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