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Tax residency in Brazil: the nebulous "definite mood"

Understand how Tax Residency in Brazil is guided by the "definite mood", and how this is important for tax planning and tax risk prevention

February 09, 2022
Vinicius Tersi

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Opinion

One of the most difficult fundamental points to convey clearly to our clients is "definite intent", the criterion chosen by Brazilian law to define the tax residence of any individual. The choice of criterion is not a bad one. However, missing information on how to comply with the requirements to cease to be a tax resident in Brazil, and the Federal Revenue of Brazil (RFB) gives superficial and confusing guidelines.

The aim of this text is to take a closer look at how the criterion chosen by the legislator works. Few positions have been taken publicly by the tax authorities; even rarer are the decisions that have dealt with the issue, both by the Administrative Council for Tax Appeals (Carf) and by the Judiciary.

But knowing about the subject makes it possible to determine whether a person should pay income tax in Brazil on a universal basis. And it also makes it clear how the lack of information opens up a wide margin for choosing the most convenient interpretation, either for the tax authorities or for the taxpayer, which is important for prior planning and risk prevention.

Why discuss tax residency in Brazil and the "definitive mood"

For those who decide to live and work abroad, being a tax resident in Brazil means submitting income earned abroad to Brazilian taxation, regardless of the countryEven if the money is never taken to Brazil. Ceasing to be a tax resident in the country means carrying out the following procedures leaving Brazil for goodwith presentation of the Declaration of Final Departure from the Country (DSDP). To do this, you need to know the requirements for ceasing to be a tax resident in Brazil and becoming a non-resident.

In addition, the Central Bank is proposing to create its own criteria for "currency residence", similar to the tax office, but for the purpose of processing information on international remittances, records of foreign capital in Brazil and Brazilian capital abroad. This promises to create even more confusion.

Definitive intent is a requirement for acquiring or maintaining tax residency in Brazil

Internal Revenue Service regulations ¹ establishes various rules regarding the tax residence in Brazil of individuals. For the purposes of this article, we will focus on two of them:

reside in Brazil on a permanent basis; or
being a non-resident Brazilian, return to the country with definite spiritYou will become a tax resident from the date of arrival.

The mention of "definite mind" is made only once, but the reference to "permanent character" is nothing more than an indirect reference to "definite mind"².

But what is a definite mood?

The expression "definite intent" does not come from the tax law, but from the concept of civil domicile. It states that "the domicile of a natural person is the place where he establishes his permanent residence“³. For civil authors⁴The civil law is talking about two elements which, when added together, result in the notion of "civil domicile":

Ânimo Definitivo é a intenção de estar vinculado a um lugar, que se torna residência — **Definite encouragement:** the intention to remain attached to a place, even when absent

a “residence“ is the objective aspect of the home, a physical place occupied by the person to be the center of their activities;

o “definite mood” (animus manendi) is the subjective aspect of domicile, what effectively "connects" the individual to that place.

The definitive mood corresponds to intention to use a place as a lasting and stable shelternot temporary. By this logic, it is worth stating that it is first necessary to identify the definitive spirit, and then the location. From there, a person develops their social relationships, their professional practice and manages their property.

In other words, the chosen location becomes "center of vital interests" of a person, whether for family, professional or any other purpose. Without a definitive intent, there is no "residence", but only a place of stay or lodging (a visit to a relative's house, hospitalization for medical treatment, a hotel room).

The tax law can choose the criterion it prefers, as long as it reveals some economic pertinence between the individual who earns income and the state that levies the income tax⁵. By choosing a criterion used by civil law, however, the Brazilian legislator also brought the insecurities of this model.

The weaknesses of using "definite intent"

Residência Fiscal no Brasil e Ânimo Definitivo: fragilidades — Tax legislation without holes

The function of domicile is to demonstrate the place where the State's action will be most effective in resolving conflicts, whether as the State-judge, the State-electoral authority, the State-tax authority, etc. That's why we talk about civil domicile, electoral domicile or tax domicile⁶.

That's why it makes sense for the state to use domicile to be able to act in several different places, wherever a person can be found most permanently. But this is the opposite of what is wanted in tax terms, where the existence of a debt to the state (the tax) must be clear and liquid.

A person with multiple moods

The Brazilian Civil Code follows the Portuguese and German tradition, which admits multiple households. This means that the same person can have a definite desire to remain in several residences at the same time.

For example, there is nothing to prevent someone with a family in Brasilia and a job in São Paulo, who owns property in both cities and travels frequently between them for work, from being domiciled in both places. Civil law is comfortable with suing this person in both Brasilia and São Paulo to discuss a contract.

However, by adopting the definite intention as a criterion for tax residence, Brazilian law becomes more permeable to situations of dual tax residenceThis is because it admits the possibility of permanent residence in Brazil even if you live in a different place. There is a risktherefore, that someone who lives and resides abroad may still have some link with Brazil that preserves their tax residence in Brazildepending on how you behave.

(Un)willingness to pay tax

As the definitive intent is subjective by nature, there is necessarily a greater margin of uncertainty in interpretation. Definitive intent derives from the taxpayer's intention, while the tax obligation is provided for directly by the law. By using a subjective criterion, the tax law creates a certain margin of opportunity for the taxpayer to choose the situation that is most convenient for them. Could the taxpayer choose to be tax resident or not?

Not so much. Brazil is not the only country that chooses a subjective tax residency criterion. This is not a problem in itself. The problem is the lack of clear limits on the application of the concept. This would be the role of the Federal Revenue Service, the Administrative Council for Tax Appeals (Carf) and the Judiciary. As Brazil is still quite closed, there have been few opportunities to clarify the issue.

What decisions applying the definitive mood reveal

Residência Fiscal no Brasil e Ânimo Definitivo: decisões judiciais e administrativas — Is it worth discussing?

The most appropriate solution we use to deal with the subjectivity of the final mood is to use theory of evidence. Based on the analysis of judicial and administrative decisions (see below), it is possible to recognize patterns of judgment that reveal what should be taken into account in a dispute against the tax authorities:

1. Arguing about the existence or loss of final intent depends on evidence

The mere declaration of the person involved or the tax authorities is not enough. Documents and testimonies must be taken into account as elements of proof when assessing the definitive intent.

This is consistent with the subjectivity of the definitive mood. Someone's intentions are not known by telepathy. It is necessary to analyze facts and circumstances in a person's life that show that they have settled in a place with the intention of staying there. And this depends on comparing different pieces of evidence, such as documents and testimonies.

2. Income tax declarations are evidence of final intent (or the loss thereof)

A delivery of the Declaration of Definitive Departure from the Country (DSDP) is evidence of the loss of the definitive intention to reside in Brazil.

Likewise, the submission of the "normal" income tax return (DAA) is proof of the maintenance of definitive intent.

One of the most extraordinary findings of the analysis of decisions is that income tax returns are not only used as evidence regarding income tax, but also in discussions about other taxes (ITCMD and Import Tax) and in non-tax matters (such as Corporate Law and Civil Procedure)..

This is perhaps the most important point: delivering the DSDP is an important piece of evidence for any discussion of Brazilian tax residency, and even for non-tax issues. The burden of proof for those who submit normal declarations while living and residing abroad is that they still have the most diverse links with Brazil. Furthermore, the tax return is a piece of evidence that the taxpayer creates for or against themselvesdepending on the context.

3. Proof of domicile (or tax residence) outside Brazil is not enough

O The Brazilian criterion allows for permanent residence in multiple places, which is why it is necessary to prove that the permanent residence in Brazil has ceased to exist in order to be considered a non-resident.

This seems to be a common mistake made even by professionals. If a person proves that he or she has a definite desire to live in another country, this does not necessarily mean that he or she has lost the desire to live in Brazil. So, in the case of non-residence, it is not enough to prove evidence of life in another country, but also to prove the severing of ties that existed in Brazil before the move.

The basis for the three conclusions above can be found in the few rulings we found on finality. These deal with a variety of topics, not just income tax:

Decision of the 1st Chamber of the Priv. TJSP on Inventory

Being in a place for the sole purpose of obtaining medical treatment for cancer is not enough to indicate a definite desire to stay there.⁷
Evidence considered:
Proof of where the deceased kept most of their assets: residential property, rural property, business establishment and branch where they held a bank account

Decision of the 2nd Chamber of the Public Prosecutor's Court of São Paulo TJSP on Tax (ITCMD)

ITCMD should not be demanded from donors who have proven that they have lost their desire to live in Brazil in order to move to Portugal.⁸
Evidence considered:
Submission of the Declaration of Definitive Departure from the Country (DSDP) in the year prior to the donation, contract for the purchase and sale of property in Portugal, proof of purchase of vehicles, health insurance, bank account ownership and other elements demonstrating definitive intent in Portugal.
It was held that the frequent trips to Brazil were made for business and family reasons, which in itself would be insufficient to constitute a definitive desire to remain in Brazil. It rejected the tax authorities' argument that the fact that the couple had spent 120 days in Brazilian territory in the year of the donation or that the money donated was in Brazil would be relevant.

Decision of the 1st Chamber of the Commercial Court of São Paulo on Corporate Law

Studying at a university in the United States for four years, with a rental agreement for a property in Boston, is insufficient to state that one has definitively lost the will to use an apartment in Brazil as a residence, even if one only visits the apartment during the vacation period.⁹
Evidence considered:
Person did not formalize the leaving Brazil for goodand filed normal income tax returns while living in the United States. He also signed an amendment to the articles of association of a company in Brazil, stating that the Brazilian apartment was his place of residence and domicile while he was living in the USA.

Decision of the 2nd Section of the STJ on Inventory

A couple moving in with one of their daughters, so that the husband can recover from hip surgery, is a move with definitive intent if there was the prospect of them moving more permanently to another daughter's apartment in the same city soon after his convalescence.¹⁰
Evidence considered:
Death certificate of the deceased wife and the widower's hospitalization form stating the new address as residence.

Decision of the 1st Panel of the STJ on Child Custody (International Child Abduction)

A short period spent in Brazil (5 months) as an experience for a divorced couple to live together and raise their children is insufficient to create a permanent home in Brazil for the children. Habitual residence maintained in Norway, where mother and father still maintained family and work ties at the time.¹¹
Evidence considered:
Testimony from the mother and father, proof of the mother's receipt of social benefits from Norway during the time the couple were in Brazil and a Norwegian court decision regarding custody of the children.

Decision of the 2nd S., 3rd Chamber, 1st Order of Carf on Tax (IRPF) - Leandro de Aguiar Case

Submission of the DAA proves interest and intention to maintain tax ties with the country (definite intent). The fact of being a tax resident in Portugal, or living and owning income and business there, is insufficient to rule out tax residency in Brazil. Taxpayer also had income, property and business in Brazil.¹²
Evidence considered:
Submission of the Annual Adjustment Declaration (DAA) instead of the Communication of Final Departure (CSD) and the Declaration of Final Departure from the Country (DSDP) during the 17 (seventeen) years of living in Portugal

Decision of the 11th Panel of the TRF3 on compensation for military personnel

A serviceman who merely rented a property in Boa Vista (RR), where he spent 2-3 days a month and where his wife and children never lived, did not take up permanent residence. For this reason, he must return the transportation allowance he received to move with his family to the new location.¹³
Evidence considered:
Date of the lease and testimony from the owner of the property in the new location regarding the actual use of the property.

Decision of the 3rd Panel of TRF 3 on Tax (Import Tax)

The owner of a vehicle who has a dual domicile in Brazil and in a neighboring Mercosur country (Paraguay) does not have to pay import tax. Vehicles bought in Paraguay for transportation between the two countries are subject to the temporary admission regime, which suspends the collection of import tax. The vehicle's import tax would be due if the vehicle's owner only intended to stay in Brazil.¹⁴
Evidence considered:
There, it was proven that the person carried out business activities in both countries (farming in Paraguay and being a managing partner of engineering and construction companies in Brazil), and therefore had a permanent presence in both countries.

Decision of the 6th Panel of the TRF3 on Tax (IRPF)

Submission of the DAA during the period in which the person lived in England cannot be canceled solely on the basis of evidence that the person lived abroad, while at the same time maintaining rural activity in Brazil.¹⁵
Evidence considered:
Income tax returns reporting income from rural activities in Brazil and omitting income from abroad (financial investments and benefits from the English government).
Additional comments:
The decision in the case was only a preliminary one, to see if there was sufficient justification for anticipating the effects of the relief sought.
In the case, an elderly woman, 92 years old, filed a lawsuit asking for the cancellation of the income tax returns filed by her accountant, in the form of an annual tax return, in order to bring her funds from England, which had never been declared in Brazil.
She said she was a non-resident, having moved abroad in 1975 and married a British citizen there. She says she only returned to Brazil for good in December 2018, after becoming a widow.
The accountant allegedly submitted income tax returns to report the results of rural activities in Brazil, without any other information. The omission of assets and income from abroad and the failure to submit the Declaration of Brazilian Capital Abroad (DCBE) were preventing funds from England from being brought to Brazil.
The main point against the lady was that, by simply canceling the income tax returns, the income tax on the rural activity would no longer have been paid regularly, since the regime applicable to non-residents is different. It is worth noting that the values of the rural activity were considered relevant, and it was carried out directly by the individual (you), and not through a legal entity.
There was no in-depth discussion of the final decision, but it is possible to state that the filing of "normal" income tax returns was unfavorable evidence, and that the taxpayer could have tried to regularize her situation administratively, directly before the RFB, before filing a lawsuit.

In summary: in any planning to live and work abroad, it is necessary to gather evidence of the reality that best suits the case. In the case of permanent departure from Brazil, this means submitting the Declaration of Permanent Departure from the Country (DSDP) and complying with other obligations. In the case of double tax residence, it is worth gathering proof of the maintenance of ties with Brazil.

But what about the other rules on tax residence in Brazil?

It is worth noting that the Internal Revenue Service's regulations include other hypotheses regarding the acquisition or maintenance of tax residency in Brazil. In particular, there are rules on the acquisition of tax residency by foreigners and the situation of people who are absent from Brazil for 12 consecutive months. This topic deserves to be detailed in a separate text.

For now, it is enough to understand that the legislator can, by law, rule out the definitive intent in specific situations, preferring another criterion. Also can use its own rules to make it easier to prove the definitive intent, presuming that it exists or that it has ceased to exist (the legal presumptions). These are rules that change the burden of proof of the status of a person as a tax resident or as a non-resident. What the law cannot do is invent, by fiction, that an individual is a tax resident in Brazil without any basis in reality.

On this blog you will always find relevant, up-to-date information on the subject and guidance on how to avoid problems with the tax authorities and other authorities. Feel free to tell us about your experience, share the content with other friends who need guidance and contact us by e-mail at contato@tersi.adv.br or via WhatsApp. Click here to send a message now.

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References:

1
SRF Normative Instruction 208/2002Articles 2 and 3.
2
The expression "permanent character" is used by Law 3.470/1958, art. 17, Caption. At no point does the tax law make direct reference to the expression "definite intent", only the RFB regulations.
3
Civil Code, art. 70.
4
PEREIRA, Caio Mário da Silva, Instituições de Direito Civil, v. I, 23rd ed., Rio de Janeiro: Forense, 2019, p. 319-320; RODRIGUES, Silvio, Direito civil, São Paulo: Saraiva, 2003, p. 105.
5
SCHOUERI, L. E. Residência fiscal da pessoa física. Direito Tributário Atual, v. 28, 2012, p. 149-172 (152-153).
6
The "tax domicile", provided for in art. 127 of the CTNTax residence is a criterion used for the inspection and administration of various taxes, and also, eventually, to define who is the competent entity in an internal conflict, when tax residence is expressly adopted to delimit the tax jurisdiction of the Union, States, Municipalities and the Federal District. In other words, it is a concept similar to the concept of "tax residence", but it is not the same thing. See XAVIER, Alberto, Direito Tributário Internacional do Brasil, 7th edition, Rio de Janeiro: Forense, 2010, p. 218. No wonder it is so difficult to distinguish "tax residence" from other concepts.
7
AgInst 0453772-61.2010.8.26.0000, TJSP, 1st Chamber of the Privy Court, rel. Paulo Eduardo Razuk, unanimous, j. 11.01.2011.
8
ApelReex 1004216-32.2017.8.26.0053, TJSP, 2nd Chamber of the Public Prosecutor's Office, rel. Claudio Augusto Pedrassi, unanimous, j. 05.12.2017.
9
AgInst 2219468-68.2019.8.26.0000, TJSP, 1st Chamber Res. D. Empr., rel. Des. Cesar Ciampolini, unanimous, j. 11.12.2019.
10
AgInt no CC 143.741/PR, STJ, 2nd S., rel. Min. Maria Isabel Gallotti, unanimous, j. 14.09.2016.
11
REsp 1.315.342/RJ, STJ, 1st T., Min. Napoleão Nunes Maia Filho, unanimous, j. 27.11.2012.
12
Ac. 2301-007.136, CARF, 2nd S., 3rd Chamber, 1st Ord. T., rel. p/ vote Cons. João Maurício Vital, majority, j. 04.03.2020.
13
AppCiv 0016907-49.2000.4.03.6105/SP, TRF3, 11th T., rel. J. Fed. Noemi Martins, unanimous, j. 26.09.2017, DOU 03.10.2017.
14
Appeal/ReeNec 0002639-37.2016.4.03.6005, TRF3, 3rd T., rel. Cecília Marcondes, unanimous, j. 23.05.2019, DJF3 27.05.2019.
15
AgInst 5022191-65.2019.4.03.0000, TRF3, 6th T., rel. Toru Yamamoto, unanimous, j. 06.03.2021.

Author

Vinicius Tersi

Vinicius Tersi is a lawyer and specialist in international tax law. He also has a degree in Accounting and a Master's in Tax Law from USP, and is familiar with different legal and accounting systems. He specializes in international transactions for entrepreneurs and families with tax residency and assets in multiple jurisdictions. He is qualified to act in Brazil and Portugal.

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Este tópico contém 10 respostas, 9 vozes e foi atualizado pela última vez 1 ano, 5 meses ago por Henrique.

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- 9 de February de 2022 at 5:16 pm #6489
  
  Vinicius Tersi
  Keymaster
  
  0
  ::
  Understand how Tax Residency in Brazil is guided by the "definite mood", and how this is important for tax planning and tax risk prevention
  
  [See the full article at Tax residency in Brazil: the nebulous "definite mood"]
- 21 de March de 2022 at 11:55 am #7310
  
  Isaac
  Participant
  
  0
  ::
  Thanks for the text. In order for a person who has been outside the country for 25 years to regain residency status, in addition to the definitive intent (intention to live and settle in the country) does he or she need to have physically returned to Brazil?
  Thank you.
- 25 de March de 2022 at 10:26 am #7311
  
  Vinicius Tersi
  Keymaster
  
  0
  ::
  Hello, Isaac!
  
  Thank you for your interest. Yes, it is necessary to physically return to Brazil. When we look at the Receita's regulations, it says that Brazilians who "have acquired the status of non-resident in Brazil and return to the country with definitive intent on the date of arrival" reacquire the status of tax resident in Brazil. So you need to have a date of arrival in Brazil for this to happen.
  
  I hope I've helped. If you need our support, just contact us at WhatsApp or by e-mail contato@tersi.adv.br!
- 22 de August de 2022 at 6:23 pm #7312
  
  Larissa
  Participant
  
  0
  ::
  Hello, the text is very enlightening. So, would it be possible for a person to maintain tax residency in Brazil if they don't declare permanent departure and return every year, before completing the 12 consecutive months? For example, he returns to Brazil after 11 months, stays for a few weeks and then returns to the other country where he has already become a tax resident.
  Could this be a way of guaranteeing dual tax residency? So someone who is an MEI would still be legal?
  I work remotely, and my intention is to move to a neighboring country and work as an MEI for the three years remaining on my contract with the company I work for, but keeping the address where I live in São Paulo, paying the DAS and declaring income tax.
  The country I'm going to recently signed an agreement with Brazil to eliminate double taxation. Would it still be a problem to try to negotiate taxes in both countries because I'm an MEI?
  Thanks for the info
- 7 de December de 2022 at 6:36 pm #7313
  
  André
  Participant
  
  0
  ::
  Thanks for the clear information
  I have a question. I've been living in the UK for ten years and have declared my departure. For inheritance reasons, I think it would be more advantageous for me to return to being tax resident in Brazil and continue my tax residence in the UK as well - in other words, dual residence.
  Is there any way to become a tax resident in Brazil again without moving permanently? I spend between 1 and 3 months in Brazil every year, divided into two or three trips. Could I use one of these entries as a "return" date to prove my permanent intention?
  Thank you
- 12 de December de 2022 at 4:20 pm #7314
  
  Vinicius Tersi
  Keymaster
  
  0
  ::
  Hello, Larissa!
  
  Thank you for the compliment and for your interest in our content.
  
  The rule deals with the possibility of "permanent exit" and "temporary exit" from the country, as described by the Federal Revenue Service.
  
  In the temporary departure format, a person is only considered a non-resident when they spend 12 consecutive months outside the country. Those who fall under this rule must comply with tax obligations in both countries in which they maintain tax residence during this 12-month period. Although an agreement to avoid double taxation between the countries helps in many respects, the obligation to comply with ancillary and main obligations in both countries remains.
  
  Even without tax residency in Brazil, it is possible to remain a partner in a legal entity incorporated in Brazil, but this situation is not compatible with the PJ's classification in Simples Nacional. The legal entity would have to change its tax regime to Lucro Presumido or Lucro Real.
  
  I hope I've helped. If you need our support, just contact us atWhatsApp or by e-mail contato@tersi.adv.br!
- 19 de December de 2022 at 11:05 am #7315
  
  Joyce
  Participant
  
  0
  ::
  Hello Vinicius! Congratulations on the article, it helped me a lot.
  
  If possible, could you please clarify a question: Regarding the ITCMD of a person who lives outside Brazil, according to the rule for donations of movable property, the tax is levied at the donor's place of residence, in this case abroad.
  
  I would like to know in the case of when the person, even if they live abroad, has a tax residence in Brazil for RFB purposes, does this also influence the conclusion that the Brazilian states could understand that the domicile is where the person actually lives or the tax residence in BR for RFB purposes.
- 26 de December de 2022 at 5:42 pm #7316
  
  SIDNEY REY VENEZIANI
  Participant
  
  0
  ::
  Great text presented and related to the definitive spirit, but I have a question. If I've been away from the country for 8 years and now in 2023 I intend to return only in August, but I don't want to file an annual tax return for 2023/2024, would you recommend that I leave in December and return at the beginning of January 2024 to consider that this would be the date of arrival back in Brazil? You would then only have to submit your annual tax return for 2024/2025.
- 9 de January de 2023 at 4:13 pm #7317
  
  Marcos
  Participant
  
  0
  ::
  Hello Vinícius, thank you for sharing a subject that very few people have mastered.
  
  My situation is as follows:
  I left Brazil at the beginning of 2018 just to travel, but with no return date. I ended up spending four years outside Brazil and only returned for two months in 2022. The first year I didn't have any income abroad, the second year I did very little volunteering and from 2020 until now I've been working in England. However, since I didn't do my DSDP, I kept investments in fixed-income brokerages, the stock market, etc. Some are for the long term and others are falling, so it wouldn't be the best time to reactivate. I've always declared my investments in Brazil but I don't declare my income abroad (since 2020) and I don't send money from here to Brazil. If possible, I would also keep my tax residence in Brazil to keep my investments, with no intention of taking money from here to Brazil. What would you recommend? Thank you.
- 24 de April de 2023 at 10:20 am #7318
  
  Jo Silva
  Participant
  
  0
  ::
  Hello,
  I've been looking for articles to study about tax residency for a long time and your articles as well as your comments and answers have been very enlightening.
  
  Due to a job offer we left Brazil (my husband and I and our school-age children). We intend to stay here (depending on how the children adapt), returning to Brazil twice a year.
  In addition, we intend to keep our home, financial investments (shares, FIIs, treasury, etc.) and rental property in Brazil.
  We have no interest in liquidating these investments and accounts as non-tax residents are not a viable alternative for us. Therefore, our intention is to maintain dual tax residency.
  There is an agreement, if I'm not mistaken, in force since 2022, to avoid double taxation between Brazil and the country we move to.
  I understand that the salary received by my husband abroad will not be taxed in Brazil (as it is employee income already taxed at source in the contributing country).
  We have no restrictions on complying with tax obligations in both countries and are willing to file tax returns in both.
  In this case, do you believe that we would be regular, acting correctly and would not suffer double taxation?
  As I'm not working at the moment, a second alternative would be to make my husband leave permanently and keep my tax residence. This way, I would continue to receive the rental income and manage our local investments.
  Thank you in advance and I look forward to your comments.
- 21 de May de 2023 at 12:02 pm #7319
  
  Henry
  Participant
  
  0
  ::
  Hi Vinicius, how are you?
  
  I have a question, I'm a Brazilian resident in Brazil and I wanted to invest in direct treasury and variable income but I want to live permanently in Portugal and I already have a residence there too, in my case I didn't want to leave Brazil permanently to maintain my rights as an investor, would it be feasible to leave the country without leaving permanently keeping the investments in Brazil earning in euros? or is it more worthwhile to invest this money in Europe even avoiding headaches and problems with double taxation?
  
  Thank you very much.
  
  Best regards.
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