Taxation | B3
Voltar

Non-resident investor

Taxation

  • Non-resident investors trading equities, derivatives and corporate bonds are exempted on capital gains;
  • Distributed profits and dividends are also exempted;
  • However, Non-resident investors from countries or jurisdictions that do not tax income or tax income lower than 20% are treated as a Brazilian investor for taxation purposes;
  • Equity market
    Income Tax
    Operation/Event Non-resident Investors Income Tax Non-resident Investors from Low-Tax Jurisdictions
    Capital Gains Exempt 15%**
    Distributed profits and dividends Exempt Exempt
    Interest on stockholders' equity* 15% 25%
    Applications in equity funds, swap operations and operations conducted in markets with future settlement, other than the exchanges 10% 15%

    * Basis for calculation: Gross value approved by issuer.
    ** Basis for calculation: Net gains.

    IOF (Financial Transaction Tax)
    Investment Financial Transaction Tax/ Câmbio Financial Transaction/ Títulos
    Stocks and ETF in stock exchange 0% for incoming resources 0%
    Stocks and ETF outside stock exchange 0% for incoming resources (a) 0%

    (a) article 15-A, XII of Decree 6,306-07, as amended by Decree # 8,023-13

  • Derivatives market
    Taxation of investors under Resolution 4,373 domiciled in non-tax heaven countries and jurisdictions
    Operation/Event Non-resident Investors Non-resident Investors from Low-Tax Jurisdictions Financial Transaction Tax/ Câmbio Financial Transaction/ Títulos Responsible for tax collection
    Futures and Options Exempt 15%** 0% for incoming resources (in stock exchange) (a) and 0% for incoming resources (outside stock exchanges) (b) 0% (a) (2) Legal representative (d)
    Swaps – Net income* 10% 22,55% ,20,0%, 17,5% e 15% according to term 0% for incoming resources (b) 0% (c) (1) Responsible for the payment/credit (d)

    * Basis for calculation: The monthly positive results of the sum of the daily settlement of the account.
    ** Basis for calculation: Net gains.

    (a) article 15-A, XIII of Decree 6,306-07
    (b) article 15-A, XII of Decree 6,306-07, as amended by Decree # 8,023-13
    (c) article32, 15nd paragraph of Decree 6,306-07
    (d) Revenue Service Instruction 1022-11, article 74.

    (1) The Financial Transaction/ Títulos is not levied on the swap operations as provided in the Revenue Service Instruction 907-09, article 12, III.
    (2) levied on the purchase, sale or expiry of financial derivatives occuring in Brazil, which, individually, result in a increased short currency exposure or reduced.

  • Fixed income

    Non-resident investors pay 15% on earnings from the Corporate Fixed Income market. However, Non-resident investors paying as domestic investors are subject to declining rates over time, as showed below:

    • 15% on earnings, for positions held for more than 720 days;
    • 17.5% on earnings, for positions held for more than 360 days and less than 720 days;
    • 20% on earnings, for positions held for more than 180 days and less than 360 days;
    • 22.5% on earnings, for positions held for less than 180 days.

     

    Taxation of investors under Resolution 4,373 domiciled in non-tax heaven countries and jurisdictions
    Investment Rates Responsible for tax collection
    Income Tax Financial Transaction Tax/ Câmbio Financial Transaction/ Títulos
    Public Bonds Exempt (a) 0% for incoming resources (d) According to investment term (1) (f) Legal representative (g)
    Private Bonds 15% (b) 0% for incoming resources (d) 0% N/A
    Fixed Income Funds 15% (b) 0% for incoming resources (d) According to investment term (2) (f) Fund´s administrator (2) (h)
    Fixed income operations with derivatives 15% (b) 0% for incoming resources (d) Legal representative (g)
    Debentures (Law #12.431/11) and 12.431/11 Debentures funds 0% (c) 0% for incoming resources (e) According to investment term (1) (f) Responsible for the payment/credit (g)
    Agriculture securities (CDA/WA, CDCA, LCA) 15% (b) 0% incoming resources (d) 0% Legal representative (g)
    Financial bills
    Real state securities (CRI)
    Real state securities according to law #12,431 (CRI according to law 12,431) 0% (c)

    (a) Law 11,312-06, article 1º and 3º.
    (b) Revenue Service Instruction 1022-11, article 68, II.
    (c) Law # 12.341-11, article 1st.
    (d) article 15-A, XII of Decree 6,306-07, as amended by Decree # 8,023-13
    (e) article 15-A, XXIII of Decree 6,306-07
    (f) article32, 1st paragraph of Decree 6,306-07
    (g) Revenue Service Instruction 1022-11, article 74.
    (h) Revenue Service Instruction 1022-11, article 74.

    (1) FIP – Participation Investment Fund, FIC-FIP – Investment Funds in quotas of Participation Investment Funds, FIEE -Emerging Companies Investment Funds.
    (2) Levied on redemptions, cessions or renegotiations traded at a 1% daily rate, decreasing in relation to the period (from 1 to 30 days) of the investent. The Financial Transaction/ Títulos is limited to the operations revenue (from 96% to 0%).

  • Others
    Taxation of investors under Resolution 4,373 domiciled in non-tax heaven countries and jurisdictions
    Investment Rates Responsible for tax collection
    Income Tax Financial Transaction Tax/ Câmbio Financial Transaction/ Títulos
    Day trade 1. In stock exchange: Exempt (e) 2. Outside the stock exchange: 15% (b) 0% for incoming resources (in stock exchange) (k) and 0% for incoming resources (outside stock exchanges) (h) 0% (o) Legal representative (p)
    IPO N/A 0% incoming recources (L) 0% N/A
    Margin call N/A 0% incoming resources (R) N/A N/A
    Interest on net equity 15% (g) 0% (m) N/A Company that pays the interest

    (a) Revenue Service Instruction 1022-11, article 68, II.
    (b) Revenue Service Instruction 1022-11, article 69.
    (c) Law 9,249-95, article 9º, 2nd paragraph
    (d) article 15-A, XIII of Decree 6,306-07
    (e) article 15-A, XII of Decree 6,306-07, as amended by Decree # 8,023-13
    (f) article 15-A, XIV of Decree 6,306-07
    (g) article 15-A, XI of Decree 6,306-07, as amended by Decree # 8,023-13
    (h) article 15-A, X of Decree 6,306-07
    (i) article32, 15nd paragraph of Decree 6,306-07
    (j) Revenue Service Instruction 1022-11, article 74.

  • Low-taxes jurisdictions
    Taxation of investors under Resolution 4,373 domiciled in tax heaven countries and jurisdictions
    Investment Rates Responsible for tax collection
    Income Tax IO/Câmbio IO/Títulos
    1. Public Bonds 2. Private Bonds 3. Fixed income funds - Long Term 1. up to 180 days: 22.5% 2. 181 to 360 days: 20% 3. 361 to 720 days: 17.5% 4. more than 720 days: 15% (a) 0% for incoming resources (h) According to investment term (2) (n) 1.Legal representative (p) 2. Responsible for the payment/credit (p) 3. Fund´s administrador (Q)
    Fixed income funds - Short Term 1. up to 180 days: 22.5% 2. 181 to 360 days: 20% (b)   Fund's administrator (Q)
    Debentures (Law #12.431/11) and 12.431/11 Debentures funds Taxed as Private bonds or Fixed income funds 0% for incoming resources (j) Responsible for the payment/credit (p)
    Fixed income operations with derivatives 1. up to 180 days: 22.5% 2. 181 to 360 days: 20% 3. 361 to 720 days: 17.5% 4. more than 720 days: 15% (a) 0% for incoming resources (h) 0% (o) Legal representative (p)
    Swaps Responsible for the payment/credit (p)
    FIP, FIC and FIEE 15% (c) 0% for incoming resources (i) 2. Fund´s administrator (Q)
    Equity Investment Fund 0% for incoming resources (h)
    Stocks 0% for incoming resources (in stock exchange) (k) and 0% for incoming resources (outside stock exchanges) (h) 0% (o) Legal representative (p)
    Futures Options 0% (o) (4)
    Day trade 20% (c) 0% (o)
    IPO N/A 0% incoming recources (L) N/A N/A
    Margin call N/A 0% incoming resources (R ) N/A Legal representative (p)
    Flexible options and OTC 15% (c) 0% incoming resources (h) 0% (o) (4)
    Dividends Exempt (f) 0% (m) N/A N/A
    Interest on net equity 15% (g) 0% (m) N/A Company that pays the interest
        The IO/Câmbio is always 0% for the outcoming investiments