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Congratulations on the articles on the site, they are very enlightening!
I've read in a few places (e.g: https://www.mazainvest.com.br/os-desafios-do-investidor-nao-residente) that the CDE would be a necessary account for non-residents who want to send money to Brazil to invest. If the person already has investments in Brazil from when they were a resident, but doesn't transfer new money for contributions or withdrawals, the account at the stock broker or bank could be kept. Is this true?
For example, before leaving Brazil, a person had an account with a stockbroker, with investments in shares, FIIs, CDBs and Treasury Direct. After leaving the country, no money was put into the account, apart from receiving income from the investments, or the sale price of an asset. No withdrawals were made. More assets were acquired, but only using the amounts received from income and sales.
Could there be a problem with the IRS in this case, since the income from these investments falls into the account with the IRPF already withheld at source, and there have been no deposits or withdrawals apart from these receipts?
Thank you in advance for your attention
Weren't the changes in CVM 64 of 2022 a step in the right direction? Before it, the "ex-Brazilian" seemed obliged to redeem everything and leave the country with their funds, or open the very limited (and very expensive) CDE account. Now it seems to have improved a lot. I understand that it needs to be digested and there needs to be more competition between banks and brokers, but it was a surprisingly better piece of legislation than the current situation. My broker (XP) told me that I could keep my investments here as if I were Brazilian (funds, stock exchange, pension plans and private bonds).
Hi Vinicius, congratulations on a very enlightening article.
Here's my question. I'm moving to Italy, but I receive dividends from a presumed profit company in Brazil. These dividends will have to be declared and there will be tax to pay. I will also have a salaried job in Italy, but taxation will be low due to the applicable deductions.
If I maintain dual tax residency, the remuneration for the work will have to be declared as income from abroad in the DIRPF, and even if I offset the tax already paid, there will probably still be a balance. Can that other tax paid on dividends be included as tax paid abroad, to increase the amount to be offset?
What is your opinion on this "Balance Sheet in Reais" for taxation of foreign subsidiaries as of Jan/2024?
I know of countries that consider subsidiaries that act as investment holding companies to be "pass through" companies and simply disregard the company and tax the assets within it as if they were in the hands of the individual, therefore when receiving income and disposing of assets.
I've also seen countries that tax that company's profit (IN THE COMPANY'S CURRENCY). If it earned $100,000, that's taxed. But taxing on the difference between "Value in Reais in Dec/2024" and "Value in Reais in Dec/2023" seems to me to be creative accounting in order to always have something to tax. The exchange rate variation of all assets would be taxed, an exaggeration in my opinion. Your opinion?
