Brazil: Brazil introduces regularisation programme for certain assets held abroad

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Brazil: Brazil introduces regularisation programme for certain assets held abroad

Pereira
Barreto

Alvaro Pereira

Gileno Barreto

On January 14, Law n. 13.254/2016 was published establishing the Special Regime of Taxation and Foreign Currency Regularisation (RERCT).

The RERCT allows individuals and legal entities domiciled in Brazil to regularise their financial resources, assets or rights of lawful origin, located outside the Brazilian territory on December 31 2014 or in earlier periods and which have not been declared or which have been incorrectly declared to the tax authorities.

Taxpayers interested in regularising their tax situation should submit to the Federal Tax Service (RFB) their declaration (with a copy to the Brazil Central Bank – BACEN) containing the list of resources, assets and rights, whose values declared should be converted into Brazilian Real. The deadline to submit the declaration is up to 210 days as from the Normative Ruling issued by the tax authorities.

The assets declared are subjected to income tax at the rate of 15%, as well as to payment of penalty at 15%, calculated on the asset values converted by the exchange rate of December 31 2014 (R$ 2,65/US$), resulting in a combined rate of approximately 30%. Note that the current effective tax rate, considering the exchange rate of December 31 2015, would be approximately 20%.

The regularisation grants amnesty with regard to: crimes against the tax system; money laundering; tax evasion; non-authorised entry and exit of foreign currency.

The special regularisation regime does not impose the repatriation of the taxpayer assets or currency; those may remain invested in foreign countries.

Interested parties are encouraged to evaluate the advantages of the Special Regime of Taxation and Foreign Currency Regularisation.

Alvaro Pereira (alvaro.pereira@br.pwc.com) and Gileno Barreto (g.barreto@lpadv.com.br)

PwC Brazil

Tel: +55 11 3674 2276 and +55 11 3879 2829

Website: www.pwc.com.br

more across site & shared bottom lb ros

More from across our site

The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR
The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth
Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty
The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
Gift this article