Layer 4: Corporate
Banking & Foreign Exchange in Brazil
Brazil has strict FX controls managed by Banco Central. Every international payment — including import settlements — must flow through authorized channels with proper documentation.
Opening a bank account in Brazil
Foreign companies with a CNPJ can open corporate bank accounts at Brazilian commercial banks. The process varies by institution but typically requires:
Standard documentation
- • CNPJ card (comprovante de inscrição)
- • Contrato Social registered at Junta Comercial
- • CPF and ID of legal representative
- • Proof of business address
- • Financial statements of the foreign parent
- • Banco Central RDE-IED registration
Major banks for foreign companies
- • Itaú Unibanco — largest private bank, strong FX desk
- • Bradesco — extensive branch network
- • Banco do Brasil — state-owned, trade finance focus
- • Santander Brasil — European parent, smooth for EU companies
- • BTG Pactual — investment banking, large transactions
- • Banco Safra — mid-market foreign trade specialist
Foreign exchange regulations
Brazil's FX market is regulated by Banco Central do Brasil (BACEN) under the New FX Framework (Lei 14.286/2021 + Resolução BCB 277/2022). Key rules:
- All FX transactions must go through authorized institutions — banks, brokers, or fintechs authorized by BACEN. No direct peer-to-peer international transfers.
- Documentation required for every transaction — commercial invoices, customs declarations (DI/DUIMP), contracts. The bank validates the underlying commercial reason.
- IOF (Imposto sobre Operações Financeiras) — federal tax on FX operations: 0.38% for import payments, 0.38% for capital inflows/outflows, 1.1% for loans under 180 days.
- No holding of foreign currency in Brazil — companies must convert to BRL. Exception: exporters can hold USD in specific foreign currency accounts (Lei 14.286/2021).
- Transfer pricing applies — intercompany payments (royalties, services, management fees) must follow arm's-length rules and may have withholding tax implications.
Paying for imports
When a Brazilian company imports goods, the FX transaction to pay the foreign supplier follows a specific flow:
Contract + invoice
Importer and exporter agree on terms (typically CIF or FOB). Exporter issues commercial invoice in USD/EUR.
FX contract (câmbio)
Importer's bank closes an FX contract (contrato de câmbio). Bank verifies documentation against Siscomex records. IOF at 0.38% is applied.
Settlement
Bank sends SWIFT payment to the exporter. Settlement typically D+1 or D+2. The exchange rate at closing is locked in.
Payment timing matters
Brazilian importers can pay for goods before shipment (advance payment), at the time of clearance, or up to 360 days after (deferred payment). Each has different BACEN reporting requirements and IOF implications. Most imports use 30–90 day payment terms.
Profit repatriation
Foreign investors can freely repatriate profits and dividends from their Brazilian subsidiary, but the process requires:
- RDE-IED registration — the original investment must be registered with Banco Central. Without this, repatriation is blocked.
- Dividends — currently tax-free for non-residents (this may change with the 2026-2033 tax reform). FX closing at the bank is straightforward.
- Interest on equity (JCP) — an alternative distribution method with withholding tax of 15% (or treaty rate). Deductible for the Brazilian entity.
- Capital repatriation — returning the original invested capital requires BACEN documentation and may trigger capital gains tax if the repatriation amount exceeds the registered investment.
- Royalties and service fees — payments to the foreign parent for IP licenses, management fees, or technical services are subject to withholding tax (15–25%) and must be registered with INPI (for IP) or BACEN (for services).
Quick reference
?What is a CNPJ?
CNPJ (Cadastro Nacional da Pessoa Jurídica) is Brazil's national business registry number — equivalent to an EIN (US), Company Number (UK), or Handelsregisternummer (Germany). Every company that imports into Brazil must have a CNPJ.
CNPJ registration guide?What is Siscomex?
Siscomex (Sistema Integrado de Comércio Exterior) is Brazil's electronic foreign trade system where all import and export declarations are filed. Managed by Receita Federal, it connects customs, tax authorities, and regulatory agencies in a single platform.
Customs clearance processDouble taxation treaties
Brazil has tax treaties with ~35 countries that can reduce withholding tax on cross-border payments. Key treaty partners for importers/investors:
Brazil has no tax treaty with the United States or China. Withholding tax defaults to 15–25% on all cross-border payments to these countries.