“Alexis, I'm taking over the São Paulo subsidiary. Three years, maybe five. My partners tell me Brazil poses no tax problems at all. Is that true?”
Brazil had 20,345 French nationals on the consular register at 31 December 2025, up from 18,774 a year earlier. That is an increase of +8.37% in one year — the strongest among the major destinations, and it puts Brazil in 20e place worldwide, 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 assets that remain in France.
No, Brazil does not pose “no tax problems”. The France–Brazil framework has two specific gaps: no treaty covers inheritance, and the exit tax deferral is not automatic. At Balmont Conseil, we start from these two findings, verified in the text of the treaty itself.
1. Why seek expert wealth management in Brazil?
Four realities, in order of cost.
- Leaving triggers the exit tax, with no automatic deferral. Brazil exchanges information with France but does not assist it with tax recovery. If you hold securities above the thresholds, the deferral must be applied for, with a tax representative and guarantees.
- No text protects your estate. The 1971 convention only covers income tax. In the event of death, France applies Article 750 ter of the General Tax Code without any treaty adjustment, and Brazil applies the ITCMD of the federated state concerned.
- The treaty exempts; it does not credit. Its Article 22 uses the exemption method with effective rate for most income. It is an older-generation mechanism, and it works in your favour.
- The wealth remains in France. In almost all the Brazilian cases we see, the property, contracts and securities have stayed in France. So it is the French side of the file that decides the outcome.
2. The France ↔ Brazil framework in five verified points
Here is the applicable framework, verified in the text of the treaty itself and in the tax authorities' annexes as at 16 September 2026.
| French nationals on the register | 20,345 at 31 December 2025 (+8.37% over one year). |
| Income tax treaty | Yes — treaty signed in Brasília on 10 September 1971, covering income taxes only. Withholding caps: dividends 15% (Article 10), interest 15%, and 10% for certain medium-term loans (Article 11). |
| Estate tax treaty | No. No treaty governs inheritance between France and Brazil. Article 750 ter of the French Tax Code applies with no treaty correction, and the Brazilian ITCMD applies on its side, depending on the state. |
| Exit tax — deferral of payment | Deferral on request, with a tax representative and guarantees. Brazil has an exchange-of-information clause with France, but no clause on assistance in tax recovery: the condition for automatic deferral 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 favourable point of this treaty. Its Article 22 provides that income taxable in Brazil is exempt from French tax, France retaining only the right to calculate your tax at the rate corresponding to your total income. Dividends, interest and royalties are the exception: they are included in the French tax base and give rise to a tax credit.
The lack of an estate tax treaty is the breaking point. Of the four destinations we reviewed at the same time as this one, two — Senegal and Tunisia — have a full inheritance chapter. Brazil has nothing. For a family whose wealth has stayed in France and one of whose children would settle there, this difference comes at a measurable cost.
The exit tax should be reviewed before the expatriation contract is signed. As the deferral is not automatic, you must apply for it, appoint a tax representative in France and provide guarantees — as much a matter of timing as of calculation, and one that cannot be put right once your domicile has moved.
What we do not show. The detail of Brazilian domestic tax law — IRPF rates, ITCMD by state, local reporting obligations — is not in this table: we have not verified it against an up-to-date primary source. It is handled with a qualified adviser in Brazil, whom we coordinate.
3. Our services: 360° support for expatriates and investors
Three workstreams, in the order of the expatriation timetable.
The exit tax costed before the decision to leave
If your securities and shareholdings exceed the thresholds in Article 167 bis of the French Tax Code, moving your domicile triggers tax on unrealised capital gains. For Brazil, the deferral is not automatic: it must be applied for, with a tax representative in France and guarantees to provide.
We cost the exposure before the decision is made, then build the file: form 2074-ET, appointment of the representative, type and amount of guarantees. A badly sized guarantee is paid for up front.
- Valuation of unrealised capital gains and testing against the Article 167 bis thresholds.
- Deferral-on-request file: tax representative and guarantees.
- Simulation of the tax relief at term, based on how long the expatriation actually lasts.
Passing on your wealth without an estate tax treaty
No text allocates taxing rights between the two states. France taxes under Article 750 ter of the French Tax Code, depending on where the assets are located, your domicile and that of each of your heirs; Brazil applies the state ITCMD to assets located in its territory.
We map your assets, establish each heir's situation and cost the net tax burden in both scenarios — death during the assignment, death after your return. The Luxembourg assurance-vie contract and the standard tools of wealth engineering are then considered in the light of these figures.
French wealth during and after the mission
Your French-source income and assets remain subject to French law: the minimum non-resident rate under Article 197 A of the French Tax Code, the option for the average rate when it is more favourable, IFI (real estate wealth tax), and social charges at the full 17.2% rate on property income and real estate capital gains.
For a three- to five-year assignment, the question is not only how to reduce tax during the expatriation, but what will still make sense on your return. We work on both at once, including the overall architecture of your wealth and what happens to your existing contracts.
4. Methodology: our way of working
We work in four stages, and at each stage you know where you stand.
- The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
- The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
- The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.
5. What the firm offers you
What concretely sets our work apart.
- Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
- A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
- Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.
Frequently asked questions on Brazil
Is there a tax treaty between France and Brazil?
Yes, just one: the treaty signed in Brasília on 10 September 1971 for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income.
It covers income taxes only. No treaty covers inheritance or gifts.
Will my Brazilian income be taxed in France?
For the most part, no. Article 22 of the treaty provides that income taxable in Brazil is exempt from French tax; France takes it into account only to set the rate applicable to your other income — the so-called 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. Automatic deferral requires a European Economic Area state, or a state bound to France both by an administrative assistance agreement to combat tax fraud and evasion and by a mutual assistance agreement on tax recovery.
Brazil meets the first condition but not the second: annex BOI-ANNX-000508, updated on 8 October 2025, does not credit it with any recovery assistance clause. The deferral must therefore be applied for, 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 side by side. France taxes under Article 750 ter of the French 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, an inheritance tax levied by each state, to assets located in its territory. Nothing guarantees that one tax can be offset against the other: that is why the asset map and each heir's domicile must be established before departure.
What withholdings apply to my dividends and interest?
The treaty caps withholding tax at 15% on dividends (Article 10) and 15% on interest (Article 11), the latter rate being reduced to 10% for certain medium-term loans and credits, with interest on public loans exempt.
These caps do not apply automatically: your tax residence must be established and evidenced to the payer.
Will I pay CSG on my French income?
Yes, at the full rate of 17.2% on your French-source property income and real estate capital gains. The partial exemption applies only to people covered by 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, favourable income tax treaty with two gaps: nothing on inheritance, and an exit tax deferral that has to be applied for rather than being granted automatically.
It is the most exposed of the four destinations we reviewed this week. Both points are dealt with before departure; afterwards, most doors have closed.
Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.
Let's review your situation
A thirty-minute conversation is enough to cost your exit tax exposure and assess your inheritance risk. You can also start with a free contract X-ray.
Other destinations
United States · Canada · Germany · Israel · Morocco · Algeria · Netherlands · Australia · Lebanon · Côte d'Ivoire · Ireland · Greece · Monaco · Andorra · Cyprus · Jordan · Mexico · Senegal · Tunisia — or return to all of our expatriation destinations.
