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G&G on the ground · São Paulo
Company Formation · Latin America

Set up a company in Brazil.

Latin America’s largest economy and the world’s 8th largest. Combined corporate tax sits at ~34% (IRPJ + CSLL). The 2026 tax reform (EC 132/2023, LC 214/2025) is overhauling the entire indirect tax system — CBS replacing PIS/COFINS, IBS replacing ICMS/ISS, transition through 2033 to a unified ~26.5% dual VAT. Grant & Graham’s new São Paulo office opened 2026 to coordinate the LatAm region.

~34% Combined CIT
~26.5% Dual VAT (2033)
215M Population
8th Global GDP
Capital
Brasília
Largest City
São Paulo
Currency
Real (BRL)
G&G Office
São Paulo
Bloc
Mercosur
Tax Treaties
35+
Quick Answer
How do you set up a company in Brazil?

The standard structure for foreign investors is a Sociedade Limitada (Ltda.) under the Brazilian Civil Code, or a Sociedade Anônima (S.A.) under Law 6,404/76 for larger operations and listing candidates. Single-shareholder operations use the Sociedade Limitada Unipessoal (SLU) introduced in 2019. You appoint a Brazilian-resident legal representative, file with the relevant Junta Comercial (state-level Commercial Registry), obtain the CNPJ corporate tax ID from the Receita Federal do Brasil, register the foreign capital with the Banco Central do Brasil (RDE-IED), and complete state, municipal, and social security registrations.

Standard formation takes 8 to 14 weeks end-to-end — Brazil is structurally higher-complexity than most LatAm markets, though the new Empresa Fácil integrated portal has materially compressed timelines since 2024. Combined corporate tax is ~34% (IRPJ 15% + 10% surtax + CSLL 9%). Withholding tax on dividends has been reinstated from 1 January 2026 under Law 15,270/2025 after decades of dividend exemption. The new CBS/IBS dual VAT system enters its pilot phase in 2026, with full transition through 2033.

Grant & Graham coordinates Brazilian formations through our new São Paulo office, opened 2026 as our LatAm regional hub. End-to-end from structure selection through Junta Comercial filing, CNPJ, RDE-IED foreign capital registration, Banco Central compliance, state/municipal/social security enrolment, and ongoing tax and statutory work.

The Brazilian Tax Position

~34% combined CIT. Indirect tax reform live from January 2026.

Brazilian corporate taxation has two distinct stories. The direct tax position is stable: IRPJ 15% + 10% surtax on profits above BRL 240,000 + CSLL 9% (20% for financial institutions) = combined effective ~34%. The reform is happening on the indirect side. Constitutional Amendment 132/2023 and Complementary Law 214/2025 are replacing PIS, COFINS, IPI, ICMS, and ISS with a dual VAT: CBS (federal, ~8.8%) and IBS (state/municipal, ~17.7%), plus a Selective Tax (IS) on harmful goods. Combined reference rate ~26.5%. 2026 is a pilot year (CBS 0.9%, IBS 0.1% for system testing without payment). Full implementation by 2033. Plus — significantly — withholding tax on dividends has been reinstated from 1 January 2026 under Law 15,270/2025.

~34%
Combined CIT
IRPJ 15% base + 10% surtax on profits above BRL 240,000 + CSLL 9% (20% for financial institutions). Unchanged by the indirect tax reform. Pillar 2 QDMTT (Additional CSLL) operational ensuring 15% jurisdictional minimum.
~26.5%
Dual VAT (target)
CBS ~8.8% (federal) + IBS ~17.7% (state/municipal) reference rate. Pilot 2026 (CBS 0.9%, IBS 0.1% test, no payment). CBS replaces PIS/COFINS in 2027. IBS phased in 2029–2032. Full implementation 2033. Basic food zero-rated; health/education/transport 60% reduced.
New 2026
Dividend WHT
Withholding tax on dividends reinstated 1 January 2026 under Law 15,270/2025. Reverses the long-standing dividend exemption. Significant change for repatriation planning and existing corporate structures. Treaty rates apply where DTTs available.
4–33%
Simples Nacional
Simplified regime for small businesses with annual gross revenue up to BRL 4.8m. Combines federal, state, municipal taxes into a single graduated payment. Common for early-stage Brazilian operations, founder vehicles, and consultancies.

Other notable items: PIS/COFINS currently 9.25% non-cumulative or 3.65% cumulative (being replaced by CBS). ICMS state VAT 17–20% (being replaced by IBS). ISS municipal services tax 2–5% (being replaced by IBS). IOF financial operations tax. CIDE remittances 10%. PIT progressive 0–27.5%. Pillar 2 QDMTT in force. Manaus Free Zone (Zona Franca de Manaus) retains IPI even after reform — for qualifying manufacturers a major preserved incentive. 35+ double taxation treaties.

Why Brazil

Nine reasons businesses choose Brazil.

Latin America’s economic powerhouse: 8th largest global economy, ~215 million consumers, dominant LatAm market position, world-class agribusiness, mining and energy bases, a maturing tech ecosystem, and historic indirect tax reform that meaningfully simplifies a system that was previously one of the most complex on the planet. The São Paulo financial centre is the gateway to the wider region.

01

Latin America’s largest market

~215 million consumers. The largest single Spanish/Portuguese-speaking market in the world (with Portugal). 8th largest global economy by GDP. Dominant LatAm position for cross-regional operations, regional headquartering, and Spanish/Portuguese product localisation. The default LatAm anchor for any global business.

02

Tax reform — structural simplification

The 2023–2033 indirect tax reform replaces five fragmented taxes (PIS, COFINS, IPI, ICMS, ISS) with a unified dual VAT (CBS + IBS). When fully implemented, Brazilian indirect tax compliance will be dramatically simpler than the current 20-year nightmare. Companies that invest in transition readiness now will have a meaningful competitive edge by 2027–2028.

03

Agribusiness powerhouse

Top-3 global producer and exporter of soy, corn, coffee, beef, sugar/ethanol, orange juice, and tobacco. Mato Grosso, Paraná, São Paulo, Rio Grande do Sul agricultural belt. Major commodity trading houses (Cargill, Bunge, ADM, COFCO, Louis Dreyfus) operate at scale. Modern agribusiness (precision agriculture, biotechnology, agtech) is advanced. Embrapa world-class agricultural R&D.

04

Pre-salt oil & energy

Pre-salt offshore oil reserves — one of the largest hydrocarbon discoveries of the 21st century. Petrobras + Shell, ExxonMobil, BP, TotalEnergies, Equinor, Repsol active operators. Net oil exporter. Plus world-leading hydroelectric capacity (~60% of grid), strong wind (Northeast Brazil), expanding solar, and global biofuels leadership (sugarcane ethanol, biodiesel).

05

Critical mineral resources

Vale is one of the world’s largest iron ore and nickel producers. Major reserves of niobium (Brazil holds ~95% of global niobium reserves), lithium (Lithium Valley in Minas Gerais), copper, manganese, bauxite, gold. Critical minerals strategy increasingly important for the green transition. Mining is one of the largest contributors to Brazilian exports.

06

LatAm’s leading tech ecosystem

Home to Nubank (LatAm’s largest fintech — ~100m customers), Stone, PagSeguro, MercadoLibre Brasil, iFood, Movile, dLocal, QuintoAndar, C6 Bank. Strong VC funding base. São Paulo is the largest tech hub in Latin America. Embedded finance, payments, e-commerce, fintech, healthtech particularly strong. Brazil produces engineering talent at scale through USP, UFRJ, ITA, Unicamp.

07

Manufacturing & aerospace

Largest industrial base in Latin America. Major auto manufacturing presence (VW, Stellantis, GM, Toyota, Hyundai, BYD). Embraer is the world’s third-largest commercial aircraft manufacturer. Strong chemicals, pharmaceuticals, steel (Gerdau, CSN, Usiminas), and electrical equipment industries. Manaus Free Zone retains IPI incentives for manufacturing even after the indirect tax reform.

08

Mercosur & trade access

Mercosur founding member (with Argentina, Paraguay, Uruguay) — access to a ~270m-person customs union. EU-Mercosur Association Agreement signed December 2024 — once fully ratified, opens preferential access to the world’s second-largest trading bloc. Active negotiations with Singapore, Canada, China, India. Strategic positioning for any global supply chain.

09

São Paulo financial hub

São Paulo is Latin America’s financial capital. B3 is the region’s largest stock exchange. Major international banks (HSBC, Citi, Santander, BNP Paribas, Standard Chartered, BTG Pactual, Itáu, Bradesco) present at scale. Sophisticated capital markets. Strong VC, private equity, and infrastructure investment ecosystem. The natural regional headquarters for any cross-LatAm operation.

Choose a Business Structure

Six legal structures — one usually fits.

For most foreign investors, the Ltda. (Sociedade Limitada) is the practical default — flexible, lower-cost, simpler governance than an S.A. The S.A. is required for larger structures, capital markets access, and ESG-rated operations. The SLU handles single-shareholder operations cleanly. Branches and rep offices have specific narrow use cases.

RECOMMENDED · LLC

Sociedade Limitada

Ltda. · Limited Liability Company

The most common structure for foreign-invested operating companies. Minimum 2 quotaholders (or 1 under SLU). No minimum capital requirement. Quotas not freely transferable to third parties without consent. Simpler governance than an S.A. Suited to most commercial, services, manufacturing, and trading operations. Filed at state Junta Comercial.

CORPORATION

Sociedade Anônima

S.A. · Joint-Stock Company

Required for businesses raising capital through share issuance, public/private listing on B3, or sophisticated governance structures. Minimum 2 shareholders, mandatory Board of Directors above thresholds, statutory auditor in many cases. Strict disclosure requirements. Used for larger operations, JVs, regulated activities, and pre-IPO entities.

SINGLE SHAREHOLDER

Sociedade Limitada Unipessoal

SLU · Single-Shareholder Ltda

Introduced 2019 (replacing the deprecated EIRELI structure). Single-shareholder Ltda variant with all the operational advantages of a regular Ltda. The vehicle of choice for single-investor foreign subsidiaries, holding companies, and founder vehicles. No minimum capital. Lower complexity than a full Ltda with multiple quotaholders.

SMALL BUSINESS

Simples Nacional Entity

MEI / Microempresa / EPP

Simplified regime entities (MEI individual micro-entrepreneur, ME microempresa, EPP empresa de pequeno porte) accessing the Simples Nacional unified tax regime. Annual gross revenue caps: MEI BRL 81k, ME BRL 360k, EPP BRL 4.8m. Simplified compliance. Rarely used by foreign investors but relevant for joint ventures with local SME partners.

FOREIGN COMPANY

Branch Office

Filial · Foreign Company Branch

Branch of a foreign company conducting business in Brazil. Requires Presidential Decree authorisation under the Civil Code — an unusual, slow and politically sensitive process. Very rarely used in practice. For foreign investors, an Ltda. or SLU subsidiary is almost always preferable. Branch authorisation typically reserved for specific sectoral requirements.

MARKET ENTRY

Representative Office

Escritório de Representação

Foreign company representation only. Limited to liaison, market research, and promotional activities. Cannot generate revenue or sign binding commercial contracts. Lower setup cost. Used by groups exploring the Brazilian market before committing to a full subsidiary. Less common in Brazil than in many other markets — most groups proceed directly to an Ltda.

MANUFACTURERS

Manaus Free Zone Entity

Zona Franca de Manaus

Ltda. or S.A. registered in the Manaus Free Zone (SUFRAMA). Substantial IPI, ICMS, federal tax incentives for qualifying manufacturing operations. Particularly relevant for electronics, motorcycles, two-wheelers, certain consumer goods. The Manaus regime is preserved even after the indirect tax reform — one of the few sector incentives the reform retains.

NOT SURE?

Talk to us first

Ltda. for most operating companies (or SLU for single-shareholder). S.A. for larger structures, regulated sectors, or pre-IPO. Simples Nacional for small businesses. Manaus FZ for qualifying manufacturers. Branch only where Presidential authorisation is strategically necessary — almost never the right answer.

Book a call →
Formation Process

From decision to live entity.

The end-to-end registration sequence for a Brazilian Ltda. in São Paulo, coordinated from our local office and senior counsel. Standard timeline 8 to 14 weeks. Brazil is structurally higher-complexity than most LatAm markets, though the new Empresa Fácil integrated portal and the 2024–2026 digital reforms have materially compressed timelines.

01

Structure & location

Ltda., S.A., SLU, branch, Manaus FZ. Operating city — São Paulo (financial centre, largest market, G&G office), Rio de Janeiro (services, energy, government-facing), Brasília (federal contracts), Curitiba (auto/industrial), Belo Horizonte (mining/critical minerals), Porto Alegre (agribusiness gateway), Manaus (manufacturing under FZ regime). Sector check against the Brazilian Foreign Capital Negative List.

02

Brazilian-resident legal representative

Brazilian law requires every foreign shareholder to appoint a Brazilian-resident legal representative (procurador) with broad powers, formalised through a notarised and apostilled Power of Attorney. Grant & Graham arranges this through senior São Paulo counsel where the foreign client has no local representative. CPF (individual tax ID) for foreign shareholders required upfront.

03

Articles drafting (Contrato Social)

Draft the Contrato Social (for Ltda.) or Estatuto Social (for S.A.) in Portuguese. Define corporate purpose, share/quota structure, management, registered office, fiscal year, governance, dividend policy. Foreign shareholder/director documents must be apostilled in country of origin and sworn-translated by a Tradutor Público Juramentado (sworn public translator).

04

Junta Comercial registration

File the incorporation package with the Junta Comercial of the state where the company will be domiciled (JUCESP in São Paulo, JUCERJA in Rio de Janeiro, JUCEMG in Minas Gerais etc.). Filing through the Empresa Fácil integrated portal where available. Certificate of Registration (NIRE) typically issued in 2–4 weeks for an Ltda; longer for S.A.

Empresa Fácil →
05

CNPJ (federal tax ID)

Obtain the Cadastro Nacional da Pessoa Jurídica (CNPJ) from the Receita Federal do Brasil. Federal corporate tax ID required for virtually all business operations. Typically issued automatically through the Empresa Fácil integration once Junta Comercial registration is complete. CPF for non-resident shareholders/directors required prior to or in parallel with CNPJ.

Receita Federal →
06

Banco Central RDE-IED registration

Register foreign capital inflow with the Banco Central do Brasil through the RDE-IED system (Registro Declaratório Eletrônico — Investimento Estrangeiro Direto). Mandatory for all foreign direct investment, regardless of size. Required before dividend remittance, capital return, or sale of the foreign-held interest. Critical for FX repatriation planning.

Banco Central →
07

State & municipal registrations

State tax registration (Inscrição Estadual) for ICMS (until full replacement by IBS in 2033). Municipal tax registration (Inscrição Municipal) for ISS (until full replacement by IBS). Municipal operating licence (Alvará de Funcionamento). Fire department licence (AVCB) where applicable. New CBS/IBS taxpayer registrations rolling out 2026–2027 under the transition.

08

Bank account opening

Open the company’s corporate bank account at a Brazilian bank (Itáu, Bradesco, Banco do Brasil, Santander, Caïxa, BTG Pactual, BNP Paribas Brasil). KYC including beneficial ownership disclosure, foreign shareholder documents (apostilled and sworn-translated), Contrato Social, CNPJ. BRL operating account; USD/EUR accounts available subject to specific requirements. FX flows via Banco Central authorised dealers.

09

Social security & labour (INSS, FGTS, eSocial)

Register with INSS (social security) for employer contributions. Register for FGTS (employee severance fund). eSocial digital labour reporting system. Employer social charges total ~28–30% of gross salary (Brazil’s labour costs are among the highest in LatAm). Strict compliance with Consolidated Labour Laws (CLT). Trade union and collective bargaining provisions to navigate.

10

Ongoing tax, statutory & reform-transition compliance

Monthly federal returns (DCTF, EFD-Contribuções, soon CBS). Monthly state returns (SPED-Fiscal/ICMS, soon IBS). Municipal monthly ISS returns (soon IBS). Annual ECD/ECF (digital accounting/tax bookkeeping). E-invoicing mandatory through NF-e/NFS-e (schemas updated 2026 for CBS/IBS fields with soft-landing penalty waivers). Transfer pricing for cross-border related-party transactions. Pillar 2 QDMTT for in-scope multinationals.

On the Ground in Brazil

São Paulo — our LatAm regional hub.

São Paulo is Latin America’s financial capital and the natural anchor for any cross-regional operation. We opened our São Paulo office in 2026 to provide on-the-ground senior coverage across Brazil and the wider Latin American market — including Argentina, Chile, Mexico, Colombia and Peru where we coordinate through trusted local counsel.

São Paulo
G&G Office · New 2026

Our newest Grant & Graham office, established 2026 to anchor our Latin American coverage. Senior practitioners on the ground in São Paulo — LatAm’s financial centre, the largest tech ecosystem in the region, and the natural regional headquarters for international groups operating across Brazil and beyond.

From São Paulo we coordinate Brazilian Ltda, S.A. and SLU formations, support the 2026–2033 tax reform transition, lead interim management mandates, run M&A advisory, and provide consultancy across the wider LatAm region.

Brazil coverage · São Paulo, Rio de Janeiro, Brasília, Belo Horizonte, Curitiba, Porto Alegre, Manaus
LatAm coverage · Argentina, Chile, Mexico, Colombia, Peru, Uruguay

What we deliver on the ground

End-to-end company formation. Ltda., S.A., SLU, branch and Manaus FZ structures. Junta Comercial filing, CNPJ, RDE-IED foreign capital registration with Banco Central, state and municipal registrations, banking.
Tax reform transition support. CBS/IBS impact assessment, ERP and e-invoicing readiness, ICMS-incentive evaluation, transition planning across the 2026–2033 phased implementation. Most groups need this work done now.
Brazilian-resident legal representation. Notarised, apostilled Power of Attorney structures for foreign shareholders. Resident director and procurador arrangements through senior local counsel.
Interim management & senior placements. Senior commercial, finance, technology and operations interim placements into Brazilian operations, drawing from G&G’s 40+ senior consultant network.
M&A advisory. Buy-side, sell-side, and joint venture advisory for cross-border transactions. Due diligence coordination, valuation, deal structuring with Brazilian and international tax considerations.
Wider LatAm regional coordination. Argentina (with RIGI / Super RIGI scoping), Mexico, Chile, Colombia, Peru, Uruguay structures coordinated through São Paulo with trusted local counsel in each market.
Indicative Costs

What it costs to incorporate & run.

All figures are indicative for a standard Ltda. in São Paulo with one foreign corporate shareholder. Brazil is higher-complexity than most LatAm markets due to multi-level tax registrations, the resident representative requirement, sworn translation costs, and (in 2026) the additional compliance overhead from the CBS/IBS reform transition. S.A. structures cost more; Manaus FZ requires sector-specific application work.

One-time setup

Junta Comercial registration fees
BRL 500–1,500
Articles drafting (Portuguese, local counsel)
USD 2,000–4,000
Apostille & sworn translation
€700–1,500
Brazilian-resident representative (annual)
USD 3,000–6,000
CPF for non-resident shareholders
USD 300/person
RDE-IED registration coordination
USD 800–1,500
Bank account opening & KYC
included
G&G advisory & coordination
from €2,500
All-in setup (Ltda. São Paulo): from €4,500–8,500

SLU comparable to Ltda. S.A. setup typically €7,500–13,000 (higher statutory governance, mandatory bodies). Manaus FZ qualifying entity adds €3,000–6,000 for SUFRAMA registration and sectoral approvals. Tax reform transition assessment (recommended for any FY 2026 setup): from €3,500.

Ongoing monthly / annual

Monthly accounting & bookkeeping
from USD 900/mo
Monthly federal returns (DCTF, EFD)
from USD 400/mo
Monthly state & municipal returns
from USD 350/mo
Payroll & INSS / FGTS / eSocial
from USD 80/emp/mo
CBS/IBS transition compliance (2026+)
from USD 400/mo
Annual ECD/ECF digital bookkeeping
from USD 3,500/yr
Statutory audit (if applicable)
from USD 10,000/yr
Typical monthly run-rate: from USD 1,800–3,500

External audit mandatory for S.A.s, financial institutions, listed companies, and large Ltdas above specific size thresholds. Transfer pricing documentation mandatory for cross-border related-party transactions above thresholds. Beneficial ownership disclosure under Brazilian AML rules.

Quick estimate

Get an estimate in 30 seconds.

Three quick questions. We will give you a realistic cost range and timeline for your situation, and route the answers straight into a fixed-price quote request from our São Paulo office.

STEP 1 OF 3
01 · STRUCTURE

Which company structure are you considering?

02 · SETUP

How is the shareholding structured?

03 · SERVICES

What do you need from us?

Laws & Regulations

The legal framework to know.

A summary of the core legislation governing companies in Brazil. Substantive work delivered through Grant & Graham’s São Paulo office and senior Brazilian legal, tax and accounting counsel.

Corporate Law

  • Civil Code (Ltda governance) Lei 10,406/2002
  • Law on Sociedades Anônimas Lei 6,404/76
  • SLU framework Lei 13,874/2019
  • Empresa Fácil & Lei da Liberdade Econômica

Tax Law

  • IRPJ & CSLL (IR/Lucro Real legislation)
  • Tax Reform EC 132/2023 + LC 214/2025
  • Dividend WHT reinstatement Lei 15,270/2025
  • Pillar 2 / QDMTT (Additional CSLL)

Labour Law

  • Consolidated Labour Laws (CLT) Decreto-Lei 5,452/1943
  • Labour Reform Lei 13,467/2017
  • eSocial digital labour reporting
  • Trade union and collective bargaining framework

Data Protection (LGPD)

  • Lei Geral de Proteção de Dados Lei 13,709/2018
  • ANPD (Autoridade Nacional de Proteção de Dados)
  • GDPR-aligned framework

Foreign Capital & FX

  • Foreign Capital Law Lei 4,131/1962
  • Banco Central RDE-IED system
  • New FX Law Lei 14,286/2021
  • Mercosur trade framework

Intellectual Property

  • Industrial Property Law Lei 9,279/1996
  • Copyright Law Lei 9,610/1998
  • Software Law Lei 9,609/1998
  • INPI (Instituto Nacional da Propriedade Industrial)
Frequently Asked Questions

Brazil, answered.

How long does it take to set up a company in Brazil?
A standard Ltda. in São Paulo typically takes 8 to 14 weeks end-to-end. An S.A. takes 12 to 18 weeks due to additional governance and disclosure requirements. The longer items in the timeline are: document apostille and sworn translation for foreign shareholder/director materials (2 to 4 weeks), CPF for non-resident shareholders (1 to 3 weeks), Junta Comercial registration (2 to 4 weeks for Ltda; 4 to 6 weeks for S.A.), CNPJ issuance via Receita Federal (typically automatic via Empresa Fácil), Banco Central RDE-IED foreign capital registration (1 to 2 weeks), state and municipal tax registrations (1 to 3 weeks), and bank account opening (2 to 4 weeks). The Empresa Fácil integrated portal and Lei da Liberdade Econômica reforms have materially compressed timelines since 2024.
Can a foreign citizen or foreign company own 100% of a Brazilian company?
Yes, in the vast majority of sectors. Brazil grants national treatment to foreign investors. 100% foreign ownership is permitted across most commercial, manufacturing, services, IT, energy, mining, and agribusiness sectors. Restrictions exist in specific areas including: rural land (with caps on foreign ownership), border zones (within 150km of borders), nuclear energy, mining of certain strategic minerals, healthcare services (some restrictions), broadcasting (subject to specific ownership limits), and certain transport activities. The Brazilian Foreign Capital Negative List should always be checked for sector-specific restrictions before proceeding.
What is the Brazilian tax reform and what changes in 2026?
The 2023–2033 indirect tax reform (Constitutional Amendment 132/2023 + Complementary Law 214/2025) is the most significant restructuring of Brazilian consumption taxes in decades. It replaces five existing taxes (PIS, COFINS, IPI, ICMS, ISS) with a dual VAT: CBS (federal) + IBS (state/municipal), plus a Selective Tax (IS) on harmful goods (tobacco, alcohol, sugary drinks). Combined reference rate ~26.5% (CBS ~8.8% + IBS ~17.7%). 2026 is a pilot year with test rates (CBS 0.9%, IBS 0.1%) shown on invoices for system testing without payment, with soft-landing penalty waivers for e-invoicing errors. 2027: CBS fully replaces PIS/COFINS. 2029–2032: IBS phases in as ICMS/ISS phase out. 2033: full implementation, ICMS/ISS/PIS/COFINS/IPI all eliminated. Direct taxes (IRPJ + CSLL ~34% combined) are unchanged by the reform.
Was dividend WHT really reinstated in 2026?
Yes. Law 15,270/2025 reinstated withholding tax on dividends paid to non-residents (and other categories) from 1 January 2026. Brazil had operated a long-standing dividend exemption (since 1996) which made the country structurally attractive for foreign repatriation. The reinstated WHT applies subject to reduced treaty rates where Brazil has double taxation treaties (35+ countries including UK, Netherlands, Spain, Portugal). For existing corporate structures, this is a significant change to repatriation planning. We coordinate impact assessments and structure reviews as part of formation projects in 2026.
Do I need a Brazilian-resident legal representative?
Yes — every foreign shareholder (corporate or individual) in a Brazilian Ltda or S.A. must appoint a Brazilian-resident legal representative (procurador) with broad powers, formalised through a notarised and apostilled Power of Attorney issued in the foreign jurisdiction. This representative receives service of process, signs Brazilian filings, and represents the shareholder before authorities. Separately, every non-resident shareholder needs a CPF (individual tax ID) issued by the Receita Federal. Grant & Graham arranges both the procurador role and CPF coordination through senior São Paulo counsel.
Is the Brazilian Real freely convertible? Can I repatriate profits?
Yes — Brazil operates a market-based FX regime, with the Real freely convertible since 1999. The new FX Law (Lei 14,286/2021, effective 2022) significantly modernised and simplified the FX framework. Profit repatriation, dividend remittance, royalty payments, capital returns, and interest are all permitted through Banco Central authorised dealers (Brazilian banks). The critical pre-requisite is that the original foreign capital inflow must have been registered with the Banco Central via the RDE-IED system — without this, repatriation is administratively blocked. With proper RDE-IED registration, FX flows are routine. The 2026 reinstatement of dividend WHT changes the tax cost of repatriation but not the mechanical FX process.
What is the Manaus Free Zone and is it still relevant after the tax reform?
The Zona Franca de Manaus (ZFM) is a federally-protected industrial free zone in Amazonas state, providing substantial IPI, ICMS, federal tax, and import duty incentives for qualifying manufacturers. It has been particularly important for electronics, motorcycle, two-wheeler, white goods, and certain consumer goods manufacturing. Crucially, the ZFM regime is explicitly preserved by the 2023 tax reform — it is one of the few sectoral incentive regimes that the reform retains. IPI continues to apply for ZFM-located entities even after federal-level IPI changes. For qualifying manufacturers serving the Brazilian and broader Mercosur markets, the ZFM remains a meaningful incentive in the post-reform landscape.
What is the Empresa Fácil portal?
Empresa Fácil ("Easy Business") is the integrated federal portal that consolidates company registration across Junta Comercial, Receita Federal (CNPJ), and state and municipal authorities into a single workflow. Rolled out progressively across Brazilian states since 2018 and significantly expanded under the Lei da Liberdade Econômica (Economic Freedom Law) reforms, it has reduced typical Ltda formation timelines from 6+ months pre-2018 to 8 to 14 weeks today. Some states are more advanced in their Empresa Fácil integration than others; São Paulo (via JUCESP) is among the more mature implementations. For 2026 incorporations, Empresa Fácil also integrates the new CBS/IBS taxpayer registrations as the reform transition proceeds.
Can Grant & Graham manage the whole process?
Yes. Grant & Graham coordinates Brazilian formations end-to-end through our new São Paulo office (opened 2026) working with senior local counsel. The full lifecycle: structure selection (Ltda, S.A., SLU, branch, Manaus FZ), Brazilian-resident representative and CPF for foreign shareholders, Articles drafting in Portuguese and notarisation, Junta Comercial filing, CNPJ via Receita Federal, Banco Central RDE-IED foreign capital registration, state and municipal tax registrations, banking, INSS/FGTS/eSocial enrolment, sector-specific licensing, and ongoing monthly/quarterly/annual tax and statutory compliance including the 2026–2033 CBS/IBS transition support. Indicative all-in setup from approximately €4,500 to €8,500 for a standard Ltda. S.A. higher. Manaus FZ requires additional SUFRAMA work.
Should I worry about Brazilian tax complexity?
Brazilian tax complexity is real — pre-reform Brazil ranked among the worst in the world for hours spent on tax compliance, with the legacy PIS/COFINS/IPI/ICMS/ISS architecture creating layered compliance across federal, state, and municipal levels. But two things matter for 2026: first, the indirect tax reform is genuinely simplifying this over the 2026–2033 transition window, and post-2033 compliance will be dramatically simpler. Second, modern Brazilian tax practice handles the complexity efficiently through SaaS-based tax tools (TOTVS, SAP localisation, dedicated tax compliance providers) plus competent local accounting. With São Paulo-based G&G coordination and senior Brazilian tax advisors, the practical reality is much more manageable than the reputation suggests. Companies entering in 2026 also have the opportunity to set up systems with CBS/IBS readiness from day one, avoiding the technical-debt issues that legacy operations face.
Is now a good time to enter Brazil?
For long-term operations in the LatAm region, the structural case for Brazil is strong: 215m consumers, LatAm’s largest economy, the dominant tech and financial ecosystem, strong agribusiness/mining/energy positions, and the genuinely transformative tax reform creating a much simpler post-2033 compliance environment. Mercosur access plus the recently signed EU-Mercosur Association Agreement open meaningful trade preferences. Friction points to plan around: structural tax complexity during the 2026–2033 transition window (groups entering now should explicitly plan CBS/IBS readiness), high labour costs and rigid labour law (CLT-based), 2026 reinstatement of dividend WHT changing repatriation economics, currency volatility (BRL has historically been volatile), and the need for trusted local counsel for ongoing compliance. With São Paulo-based G&G coordination, an upfront structural decision, and modern tax/accounting tooling, the practical experience of doing business in Brazil is materially better than the reputation suggests.
How We Work

Four steps from enquiry to live entity.

01 · CONSULT

Discovery call

30-minute conversation to understand your business, sector, city preference, Ltda vs S.A. vs SLU, Manaus FZ eligibility, foreign capital structure, and tax reform readiness. Honest assessment of fit.

02 · SCOPE

Recommendation

Senior advisory on the right structure, city, registered capital, resident representative arrangements, banking partner, CBS/IBS transition implications. Fixed quote in EUR or USD.

03 · INCORPORATE

End-to-end formation

Junta Comercial, CNPJ, RDE-IED Banco Central, state/municipal registrations, INSS/FGTS, banking, sector licensing. São Paulo-coordinated, executed through senior local counsel.

04 · OPERATE

Ongoing support

Retained accounting, monthly federal/state/municipal returns, payroll/INSS/FGTS/eSocial, CBS/IBS transition compliance, annual ECD/ECF, statutory audit if applicable, transfer pricing, Pillar 2 QDMTT.

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Ready to incorporate in Brazil?

Tell us in 25 minutes what you need. We will tell you honestly whether Brazil is the right fit, which structure makes sense (Ltda, S.A., SLU, Manaus FZ), how the 2026–2033 tax reform transition affects your situation, and which city — then handle the setup end-to-end through our São Paulo office and senior Brazilian counsel.