«"Alexis, I'm taking over the management of the subsidiary in São Paulo. Three years, maybe five. My partners tell me that Brazil doesn't present any tax problems. Is that true?"»
Brazil had 20,345 French citizens registered with the consulate as of December 31, 2025, compared to 18,774 a year earlier. This represents an increase of +8.37 % in one year — the strongest of the major destinations, and it places Brazil at 20e world ranking, just behind Mexico.
This growth stems from a specific trend: executives and managers sent to São Paulo, Rio, and the Northeast by French companies for three- to five-year terms. The profile is therefore that of a fixed-term professional expatriation, with a wealth that remains in France.
No, Brazil does not pose "no tax problems." The Franco-Brazilian framework has two specific loopholes: No agreement governs inheritances., and the deferral of exit tax is not automatic there. Balmont Conseil, We start from these two observations verified in the text of the convention itself.
1. Why seek expertise in wealth management In Brazil?
Four realities, in the order they cost.
- Departure triggers the exit tax, without automatic deferral. Brazil exchanges information with France, but does not assist in debt recovery. If you hold securities exceeding the thresholds, a deferral must be requested, with a tax representative and guarantees.
- No text protects your inheritance. The 1971 convention only covers income tax. In the event of death, France applies Article 750 ter of the General Tax Code without modification, and Brazil applies the ITCMD of the relevant federated state.
- The convention exempts, it does not credit. Article 22 of the law retains the method of exemption with an effective rate for the majority of income. This is an older system, and it works in your favor.
- The wealth remains in France. In almost all the Brazilian cases we've seen, the real estate, contracts, and securities have remained in France. Therefore, it's the French side of the case that determines the outcome.
2. The France ↔ Brazil framework in five verified points
Here is the applicable framework, verified in the text of the convention itself and in the annexes of the tax administration as of September 16, 2026.
| French registered in the register | 20,345 as of December 31, 2025 (+8.37 % over one year). |
| Income Convention | Yes — convention signed in Brasília on September 10, 1971, relating solely to income taxes. Capped withholdings: dividends 15 % (article 10), interest 15 % and 10 % for certain medium-term loans (article 11). |
| Convention on Successions | No. No treaty governs inheritance between France and Brazil. Article 750 ter of the French General Tax Code applies without any treaty amendment, and Brazilian inheritance tax (ITCMD) applies according to the state. |
| Exit tax — deferral of payment | Optional suspension, with tax representative and provision of guarantees. Brazil has an information exchange clause with France, but no assistance clause for recovery: the condition for a legal stay of execution is not met. |
| CSG and CRDS on property income and capital gains | 17.2 %. The exemption from CSG and CRDS applies to members of a social security scheme in the European Economic Area, Switzerland, or the United Kingdom. Brazil does not fall into any of these categories. |
The elimination method is the strong point of this convention. Article 22 of the law stipulates that income taxable in Brazil is exempt from French tax, with France retaining only the right to calculate your tax at the rate applicable to all your income. Dividends, interest, and royalties are exceptions: they are included in the French tax base and give rise to a tax credit.
The absence of an inheritance agreement is the breaking point. Of the four destinations we examined concurrently with this one, two—Senegal and Tunisia—have comprehensive inheritance laws. Brazil has none. For a family whose assets have remained in France and whose child settles there, this difference is significant.
The exit tax should be considered before signing the expatriation contract. Since the stay of execution is not a right, it must be requested, a tax representative must be appointed in France and guarantees must be provided — a task of scheduling as much as calculation, which cannot be made up for once the residence has been transferred.
What we don't display. The details of Brazilian domestic tax law—IRPF tax rates, ITCMD by state, local reporting requirements—are not included in this table: we have not verified them in a current primary source. This information should be discussed with an authorized advisor in Brazil, whom we coordinate.
3. Our services: 360° support for expatriates and investors
Three projects, in the order of the expatriation schedule.
The exit tax calculated before the departure decision
If your securities and equity interests exceed the thresholds set out in Article 167 bis of the French General Tax Code, transferring your tax residence will trigger the taxation of unrealized capital gains. When transferring to Brazil, a deferral of taxation is not automatic: it must be requested, with the appointment of a tax representative in France and the provision of guarantees.
We calculate the exposure costs before a decision is made, then we prepare the file: declaration 2074-ET, designation of the representative, nature and amount of guarantees. An inadequate guarantee will be paid for immediately.
- Evaluation of unrealized capital gains and testing of the thresholds of article 167 bis.
- Optional deferment file: tax representative and guarantees.
- Simulation of the tax relief at the end, according to the actual duration of the expatriation.
The transfer, in the absence of a succession agreement
No text allocates the right to tax between the two states. France taxes according to Article 750 ter of the General Tax Code, based on the location of the assets, your residence, and that of each of your heirs; Brazil applies the ITCMD of the federated state to assets located within its territory.
We map your assets, establish the situation of each heir, and calculate the net burden in both scenarios — death during the mission, death after return. Luxembourg assurance-vie contract and the classic tools of wealth engineering They then look at each other, in light of this calculation.
French wealth during and after the mission
Your income and assets of French origin continue to be subject to French law: minimum rate for non-residents under Article 197 A of the General Tax Code, option for the average rate when it is more favorable, real estate wealth tax, social security contributions at the full rate of 17.2 % on property income and real estate capital gains.
For a three- to five-year assignment, the question is not only about reducing taxes during expatriation, but also about what will remain consistent upon return. We consider both aspects simultaneously, including the overall architecture of your wealth and the fate of your existing contracts.
4. Methodology: our way of working
We work in four stages, and you know where you are at each stage.
- The initial assessment. We assess your actual situation: composition of assets, project timeline, situation of each member of the household, and tax domicile of your heirs — because it is theirs that dictates, not yours.
- The applicable reference framework. We establish, source by source and with its date, the framework that concerns you. What we do not know, we write "to be confirmed" — never anything else.
- The arbitrations. We present you with the numerical options, along with their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- The follow-up. An annual review, offered free of charge, which verifies that the framework has not changed — the conventions are modified, the attractiveness schemes are eliminated, the thresholds change.
5. What the firm offers you
This is what specifically distinguishes our intervention.
- Sources, not claims. Each item in your file has its reference number and date. You can check. This is the only way to work on a subject where most of the information available online is outdated.
- A single point of contact in France. We coordinate with your local advisors, we do not replace them: the internal tax regulations of the host country are handled by a qualified professional on site. Our role is to maintain overall consistency and to defend the French side of the case.
- Fees that are easy to understand. Firm fees: €500 including VAT per hour. Annual follow-up is included. No hidden kickbacks, no performance-based billing.
Frequently Asked Questions in Brazil
Is there a tax treaty between France and Brazil?
Yes, only one: the convention signed in Brasília on September 10, 1971, aimed at avoiding double taxation and preventing fiscal evasion with respect to taxes on income.
It only covers income taxes. No agreement covers inheritances or gifts.
Will my Brazilian income be taxed in France?
Essentially, no. Article 22 of the convention provides that income taxable in Brazil is exempt from French tax; France only takes it into account to determine the rate applicable to your other income, which is called the effective rate rule.
Dividends, interest and royalties are an exception: they are included in the French taxable base and entitle the taxpayer to a tax credit corresponding to the Brazilian tax.
Is the deferral of payment of the exit tax automatic for Brazil?
No. The deferment by right requires a State of the European Economic Area, or a State linked to France both by a convention on administrative assistance against tax fraud and evasion and by a convention on mutual assistance in matters of recovery.
Brazil meets the first condition but not the second: Annex BOI-ANNX-000508, updated on October 8, 2025, does not recognize any clause providing assistance with tax recovery. Therefore, a deferment must be requested with a tax representative and guarantees.
What happens to my estate if I die during my stay in Brazil?
In the absence of a treaty, two systems apply in parallel. France taxes according to article 750 ter of the general tax code: assets located in France, all assets if you were domiciled there, and all assets received by an heir domiciled in France for at least six of the last ten years.
Brazil applies the ITCMD, a state inheritance tax, to assets located within its territory. There is no guarantee that one tax will offset the other; therefore, a mapping of assets and the residence of each heir must be established before departure.
What withholdings apply to my dividends and interest?
The convention caps the withholding tax at 15 % on dividends (article 10) and at 15 % on interest (article 11), the latter rate being reduced to 10 % for certain medium-term loans and credits and interest on public loans being exempt.
These limits do not apply automatically: they assume that your tax residence is established and justified to the payer.
Will I pay CSG on my French income?
Yes, at the full rate of 17.2% (%) on your French-source rental income and capital gains. The partial exemption applies only to those affiliated with a scheme in the European Economic Area, Switzerland, or the United Kingdom.
This is the point most often overlooked in rental yield simulations done before departure: on a rented property, it weighs more heavily than income tax itself.
In summary
Brazil combines an old and favorable convention on income with two gaps: nothing on inheritances, and a deferral of exit tax that is requested instead of obtained.
This is the most exposed of the four destinations we investigated this week. Both issues are addressed before departure; afterwards, most doors have closed.
Firm's fees: €500 including VAT per hour. Annual follow-up is offered.
Let's review your situation
A thirty-minute consultation is all it takes to calculate your exposure to exit tax and assess your inheritance risk. You can also start with a Free X-ray of your contracts.
Other destinations
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