Taxation of international executives
A foreign national is subject to Brazilian income tax on their worldwide income once they become a resident of Brazil for tax purposes. As a resident, their taxable income cannot be reduced by an allocation of income to days worked outside Brazil. In general, any remuneration received for services rendered by a resident foreign national constitutes taxable income.
A foreign national that is a non-resident of Brazil for tax purposes is not subject to tax on remuneration paid outside Brazil. A non-resident is subject to a flat tax of 25 percent on remuneration paid in Brazil.
An individual’s tax liability is due on a monthly basis as income and gains are realized. The tax on salaried income paid by a Brazilian entity is withheld at the source. Thus, an individual who is paid on a Brazilian payroll from only one employer during the year would not have any tax due when the annual income tax return is filed, provided the taxes were withheld properly. However, the individual may be entitled to certain deductions, which may be claimed on the annual tax return, in which case they may be entitled to a tax refund when the annual return is filed.
Income received abroad by a Brazilian tax resident must be reported and the corresponding tax paid by the last day of the month following the month the income was received. The monthly “Carnê-Leão” must be completed and the taxable base includes all remuneration and benefits paid abroad to a Brazilian tax resident and all other income (such as interest, dividends, and rental income). All income received abroad is subject to a monthly tax in accordance with the progressive tax rate table.
The official currency of Brazil is the Brazilian Real (BRL).
Herein, the host country/jurisdiction refers to the country/jurisdiction to which the employee is assigned. The home country/jurisdiction refers to the country/jurisdiction where the assignee lives when they are not on assignment.
All information contained in this publication is summarized by KPMG Assessores LTDA, the São Paulo - Brazil member firm affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity, based on the Brazilian Tax Code – 9580 on 11 November 2018 and subsequent amendments; Law 8,036/ 1990 and subsequent amendments; Law 8,213/ 1992 and subsequent amendments and Normative Instructions provided for the Brazilian Tax Authorities.- website – receita.fazendo.gov.br.
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