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Structuring Offshore Companies and Investments Legally

Offshore entities and trusts can be legitimate tools for:

  • asset protection
  • succession planning
  • portfolio diversification
  • currency risk mitigation
  • international business operations

However, Brazil applies strict rules to foreign structures, especially after the enactment of Law 14.754/2023, which introduced:

  • annual taxation of offshore income,
  • transparency rules for controlling individuals,
  • changes to trust treatment,
  • stricter valuation and reporting standards.
  • Expats must ensure:
  • proper reporting on the IRPF (Brazilian tax return)
  • valuation of assets according to Brazilian rules
  • compliance with the CBE (Brazilian Capitals Abroad)
  • alignment of trust or corporate documents with Brazilian tax definitions
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