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Withholding tax on remittances abroad from Brazil

Last verified: 2026-10-25

Payments from Brazil to non-residents are generally subject to 15% income tax withholding, rising to 25% for beneficiaries in low tax jurisdictions and for non-technical services. Royalties and technical services also carry a 10% CIDE paid by the Brazilian payer, plus import PIS, COFINS and ISS on services. Dividends bear 10% from 2026 and interest on equity 17.5%.

The rule

1. Income, capital gains and other amounts paid to non-residents without a specific rule are subject to 15% withholding.Decree 9,580/2018 (RIR), art. 744, 2018-11-22 official text

2. Income of residents in jurisdictions classified as having favored taxation is subject to 25% withholding.Decree 9,580/2018 (RIR), based on Law 9,779/1999 art. 8, art. 748, 2018-11-22 official text

3. A favored tax jurisdiction is one that does not tax income or taxes it at a maximum rate below 17%.Law 9,430/1996, as amended by Law 14,596/2023, art. 24, 2023-06-14 official text

4. Remuneration for work and for services paid to non-residents is subject to 25% withholding, except technical services and technical or administrative assistance under RIR art. 765.Decree 9,580/2018 (RIR), based on Law 9,779/1999 art. 7, art. 746, 2018-11-22 official text

5. Technical services and technical, administrative and similar assistance are subject to 15% withholding.Decree 9,580/2018 (RIR), art. 765, 2018-11-22 official text

6. Royalties of any kind remitted abroad are subject to 15% withholding.Decree 9,580/2018 (RIR), art. 767, 2018-11-22 official text

7. CIDE at 10% is due by the Brazilian company on payments for technology licences and transfer, trademark and patent use, technical services and administrative assistance, and royalties of any kind to non-residents. Software licences without transfer of technology are excluded.Law 10,168/2000, as amended by Law 10,332/2001, art. 2, paras. 1, 1-A, 2 and 4, 2000-12-29 official text

8. Dividends remitted abroad bear 10% withholding from 2026; interest on equity bears 17.5%.Law 9,249/1995, art. 10, para. 4; art. 9, para. 2, 2025-12-26 official text

9. PIS and COFINS on imported services are 1.65% and 7.6%.Law 10,865/2004, art. 8, item II, 2004-04-30 official text

10. ISS also applies to services coming from abroad or whose provision began abroad.Complementary Law 116/2003, art. 1, para. 1, 2003-07-31 official text

11. Remittances of profits, dividends, interest, royalties and technical assistance require the contracts and documents that the BCB and the Receita Federal deem necessary.Decree 9,580/2018 (RIR), based on Law 4,131/1962 art. 9, art. 774, 2018-11-22 official text

Worked example

A Brazilian subsidiary pays BRL 1,000,000 of trademark royalties (about USD 198,503) to its non-haven parent. Withholding 15%: BRL 150,000 (about USD 29,775). CIDE 10% borne by the payer: BRL 100,000 (about USD 19,850). If the contract is net of tax and the payer grosses up, the gross becomes about BRL 1,176,471 and withholding about BRL 176,471. If the same licensor sat in a jurisdiction with a maximum income tax rate below 17%, withholding would be 25%. USD at the BCB PTAX selling rate of 23 October 2026, BRL 5.0377 per USD.

Step by step

Classify each payment: dividend, JCP, interest, royalty, technical service, other service. The rate depends on the classification.
Screen the beneficiary's jurisdiction against the Receita Federal list of favored tax jurisdictions and privileged regimes.
Check the treaty, if any, for reduced rates and documentation requirements.
Compute and pay withholding, CIDE, import PIS and COFINS and ISS before or at the FX settlement.
Register and document the underlying contract so the bank can process the FX contract.

Common traps

Treating all services as technical: non-technical services default to 25%.
Forgetting CIDE, which is a cost to the payer and is not creditable abroad as income tax.
Ignoring the gross up when contracts promise the licensor a net amount.
Assuming dividends are still exempt from withholding.

Sources

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