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Brazil's double tax treaties

Last verified: 2026-10-25

Brazil's treaty network is narrower than most large economies. The Receita Federal index lists 39 jurisdictions, one of which, Germany, has had no treaty effect since 1 January 2006. There is no income tax treaty with the United States or the United Kingdom on that list. Recent additions include the UAE, Switzerland, Singapore and Uruguay, and protocols with China and Chile took effect in 2026.

The rule

1. The Receita Federal index of double tax treaties lists: South Africa, Germany (without effect since 1 January 2006), Argentina, Austria, Belgium, Canada, Chile, China, South Korea, Denmark, United Arab Emirates, Ecuador, Slovakia, Spain, Philippines, Finland, France, Hungary, India, Israel, Italy, Japan, Luxembourg, Mexico, Norway, Netherlands, Peru, Poland, Portugal, Czech Republic, Russia, Singapore, Sweden, Switzerland, Trinidad and Tobago, Turkey, Ukraine, Uruguay and Venezuela.Receita Federal treaty index, page updated 28 August 2026, 2026-08-28 official text
2. The treaty with the United Arab Emirates was promulgated by Decree 10,705/2021.Decree 10,705/2021, promulgation, 2021 official text
3. The treaty with Switzerland was promulgated by Decree 10,714/2021.Decree 10,714/2021, promulgation, 2021 official text
4. The treaty with Singapore was promulgated by Decree 11,109/2022.Decree 11,109/2022, promulgation, 2022 official text
5. The treaty with Uruguay was promulgated by Decree 11,747/2023.Decree 11,747/2023, promulgation, 2023 official text
6. A protocol amending the China treaty was promulgated by Decree 12,620/2026, and a protocol amending the Chile treaty by Decree 12,863/2026.Decrees 12,620/2026 and 12,863/2026, promulgation, 2026 official text
7. Slovakia and the Czech Republic are covered by the treaty with former Czechoslovakia, Decree 43/1991.Decree 43/1991, promulgation, 1991 official text

Worked example

A US parent receiving BRL 1,000,000 of dividends (about USD 198,503) from a Brazilian subsidiary bears the domestic 10% withholding, BRL 100,000, with no treaty to reduce it, and relies on its home country foreign tax credit rules. A parent in a treaty country should check the dividend article of its treaty and protocol. USD at the BCB PTAX selling rate of 23 October 2026, BRL 5.0377 per USD.

Step by step

  1. Confirm the treaty is on the Receita Federal index and in force for the year of payment.
  2. Read the treaty with its protocol and any Ministry of Finance ordinance on application methods.
  3. Check beneficial ownership, limitation of benefits and documentation requirements.
  4. Apply the treaty rate at source and keep residence certificates.

Common traps

  • Assuming a treaty exists with the US, the UK or Germany.
  • Relying on a signed treaty that has not been promulgated by decree.
  • Assuming every treaty limits the new dividend withholding below 10%.

Sources

Related pages

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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