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 2025

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

It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Indirect tax professionals now rate compliance as a bigger obstacle than technology and automation; in other news, Italy approved a VAT cut on art sales
AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool
Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
Gift this article