International & Offshore

All of your wealth depends on a single country

If your company bills in reais, your real estate is in Brazil and your investments are too, you do not have a diversified portfolio: you have a concentrated bet on the same economy, the same currency and the same legal system. Investing abroad is not fleeing the country or hiding money: it is an operation declared to the Receita (Brazil's federal tax authority) and to the Central Bank, with clear rules. I explain the mechanism, and where it stops being worth it.

01Currency and asset are two separate risks

02The money leaves the country; the declaration does not

When this becomes a real problem

You buy dollars thinking you have diversified. You changed currency, yes, but money sitting in dollars is not an investment, it is a currency position. Diversifying currency and diversifying assets are two different decisions, and it is common to make one thinking you made both.
Your children live, study or plan to live abroad. Your future spending is in dollars, euros or pounds, but one hundred percent of your wealth is in reais. That is a mismatch between the currency of the liability and the currency of the asset, and the exchange rate decides the outcome.
You already have an account or property abroad, set up on someone's recommendation, and you cannot say with confidence whether it is correctly declared to the Receita and to the Central Bank. The doubt itself is already the problem.
Someone suggested "opening an offshore" and the word sounded like tax evasion. You backed off. Or, worse, you agreed without understanding what you were signing and who is answerable for it.

How it works in practice

Currency and asset are two separate risks

Every investment abroad has two engines: which asset you bought and which currency it is in. A foreign-exchange fund or dollars in an account change only the currency: they protect those with expenses abroad, but do not put the money to work. A US equity ETF changes both: you come to depend on that market and on the exchange rate at the same time. And there is the middle path: BDRs (Brazilian Depositary Receipts) and Brazilian funds holding international assets give economic exposure abroad, with custody and settlement here in Brazil, in reais. There is no better option in the abstract. There is the one that fits where your expenses will occur over the next ten years.

International account: the money leaves the country, the declaration does not

Sending funds abroad is a formal foreign-exchange operation: a contract, the nature of the operation declared (investment, not "generic transfer") and IOF (Brazil's tax on financial transactions), whose rate changes depending on the nature and has been altered several times, so it is worth checking the one in force on the date of the remittance. On the other side, the assets are held in custody abroad, in an account in your name, under the law of that country. What really changes is the jurisdiction of the custody. What does not change: you remain a Brazilian tax resident, and you still owe information to the Receita and to the Central Bank about it.

A real offshore is a company, not a hiding place

An offshore is a legal entity incorporated outside Brazil (Delaware, Uruguay, the British Virgin Islands, whichever it may be), of which you are the shareholder, with a CNPJ (Brazilian company tax ID) or equivalent, accounting, a local agent and an annual maintenance cost. It appears in your income tax return as an equity interest, at acquisition value. It is not secret: Brazil takes part in the international standard for automatic exchange of financial information, so institutions abroad report the accounts of Brazilian residents to the Receita. The opacity the word suggests ended years ago. What is left is an organizing tool: consolidating investments spread around under a single ownership and defining in the articles of association what happens to that wealth when the holder dies.

The rule changed: the tax no longer waits for the redemption

Until recently, profit from a structure abroad was taxed only when the money came back to Brazil. The so-called Offshore Law (Law 14,754/2023) changed that: income from financial investments abroad and profits of controlled entities are now calculated and taxed annually in the tax return, at a specific rate set by law, even if nothing is repatriated. In other words: whoever set up a structure counting on deferral of the tax lost its main economic reason. Today the argument in favor is organization and succession, not tax savings, and the exact calculation for your case is for your accountant.

Where the money sits is also a choice

International life insurance policy: a structure, not a life insurance

There is an instrument in the international market that confuses almost every Brazilian in the first conversation: the unit-linked life policy, also called a wrapper. You contribute an amount, the insurer issues a policy and the investments you chose come to live inside it, held in custody by a third party. The death-risk component is small on purpose. What matters is the legal effect of the wrapper: instead of a list of scattered accounts, there is a contract with a named beneficiary, and that changes how the wealth is transmitted. It is the same reasoning as on my insurance page, applied abroad: the subject is allocation and liquidity, not returns. And it is an expensive contract to maintain, because the wrapper's fee adds to the fees of the funds inside it. Below a certain volume, the numbers simply do not work, and this is the kind of thing that has to be calculated beforehand, not afterward.

Why the Isle of Man shows up in every offshore conversation

The Isle of Man lies in the Irish Sea, is a self-governing Crown Dependency of the British Crown and is part of neither the United Kingdom nor the European Union. It has its own laws, a judiciary based on English common law and its own parliament, the Tynwald, in continuous operation for more than a thousand years. Moody's assigned the island an Aa3 rating in December 2024, and it has accumulated 50 consecutive years of budget surplus. Under the local tax regime there is no capital gains tax, withholding tax or wealth tax. None of this exempts you from anything: you remain a Brazilian tax resident, and the assessment that counts is the one here, with Law 14,754/2023 on top. What the jurisdiction delivers is not lower tax for the Brazilian investor. It is predictability of rules and protection of the policyholder, which are different things and are often sold one for the other.

Investor protection, in verifiable numbers

Since 2018, the island's financial authority (IOMFSA, the Isle of Man Financial Services Authority) has required insurers to hold solvency capital sized to absorb a 1-in-200-year shock over a one-year horizon, above technical provisions. Since 2019, a Business Conduct Code has required transparency of the fees charged to the policyholder and imposes a minimum 30-day period for cancelling the policy. There is also a policyholders' compensation fund: if the insurer becomes insolvent, the policyholder can receive up to 90% of its obligation relating to the policy, wherever they live. It is worth rereading that last sentence slowly. The fund covers the failure of the insurer, not a fall in the assets you chose to put inside the policy. If the fund in there drops 30%, nobody makes it up. Structure protection and market risk are two subjects that do not meet.

The structure I operate, with all three names on the table

Commercial material for structures abroad tends to stack seals that speak of different things, so I prefer to open mine before you ask. Jurisdiction: Isle of Man, rated Aa3 by Moody's in December 2024, regulated by the IOMFSA. Insurer: RL360 Insurance Company Limited, registered on the island under number 137548C and licensed by the IOMFSA, born in 2008 from the merger of Scottish Life International (1996) with Scottish Provident International (1991); it received a B+ financial strength rating from AKG in December 2024 and is part of the IFGL group, which manages USD 27 billion for 214,000 client policies in 200 countries, with Cinven as majority shareholder since January 2023. Custodian: Citibank N.A. or Allfunds, with annual audit by PwC in the Isle of Man. A custodian separate from the insurer is precisely what prevents the balance sheet of one from becoming the problem of the other, and it is the name that appears least in brochures and matters most on the day of the problem. Two warnings that are part of the same conversation: B+ is a good rating from an agency specialized in insurers, it is neither the top rating nor a sovereign rating, and the policy has its own maintenance cost that adds to the fees of the funds inside it. You also have 30 days of cancellation guaranteed by the island's regulation after signing. If you like, I will send you the documents of all three before any conversation about product or amounts.

Succession freedom there does not erase the forced heirship here

In the Isle of Man there is no forced heirship. Because it follows English common law, the holder freely names who receives, whether by naming a beneficiary on the policy or through a trust. It is the opposite of Brazil, where half of the estate is the legítima (the share reserved by law) of the necessary heirs. From this contrast comes the most repeated sales argument in the sector, and also the most dangerous. You are domiciled in Brazil and a Brazilian tax resident: your succession will be discussed here, before a Brazilian judge, and the island's freedom of designation does not repeal the legítima of the Civil Code. What the structure can do is organize the transmission and deliver quick liquidity to whoever you named. What it does not do is disinherit those whom Brazilian law protects. Anyone who promises that is selling a lawsuit to your children. That specific conversation is for a succession lawyer, not me, and I prefer to say so before you sign.

RL360 and IFGL data as of December 31, 2024, according to material published by the group itself.

What I do for you

I map the mismatch before talking about products: where your future expenses are, in which currency, over what time frame. Without that, choosing an asset is a guess.
I separate with you the two decisions: how much of your wealth makes sense to hold outside the real, and what that money will buy once it leaves.
I show the four paths side by side (exposure through Brazilian assets, an international account in your name, an international policy and a corporate structure abroad) with the real cost and complexity of each, including when the simplest one is the right one.
I operate the opening of the international account and platform within BTG Pactual and distribute the international policy of RL360, an insurer based in the Isle of Man and licensed by the IOMFSA, for the cases where the wrapper solves what an account alone does not. In both, the funds are held in custody in your name, never with me, and the documents of the institution, of the custodian and of the regulator reach you before any conversation about amounts.
I work together with your lawyer and your accountant when the case calls for a structure. If you do not have them yet, the guidance is not to set up the structure before having them. I do not do the legal or the tax part, and we do not pretend that I do.
I leave in writing what has to be declared every year and by whom, so the structure does not become a silent liability in your hands.

What this does not solve

A structure abroad stopped being a tax shortcut after Law 14,754/2023: the tax effect in your case is for your accountant to determine. It also does not protect against creditors in fraud and does not disappear from the Receita's radar. Today it is the opposite: it gives more visibility, not less. It costs incorporation, annual maintenance, a local accountant and your attention every April; below a certain volume of wealth, that cost eats any benefit and the honest answer is do not do it. Investing abroad is also not a synonym for safety: there is no FGC there (Brazil's deposit guarantee fund), the exchange rate can work against you for years in a row, and the protection mechanisms that exist abroad vary from country to country, and where they exist, they deal with the failure of the institution, never with market loss; it is worth checking case by case which one applies to your account. International diversification reduces dependence on a single country. It does not reduce risk to zero, and anyone who promises that is selling something else.

Frequently asked questions

Is investing abroad legal? Do I have to declare it?

It is legal and it is declared. A Brazilian tax resident reports assets held abroad in the income tax return, at acquisition cost, and calculates the income according to the legislation in force. There is also the declaration of Brazilian Capital Abroad, filed with the Central Bank when the total held abroad exceeds a value threshold set by the Central Bank. That threshold has changed before, so it is worth checking the one in force for the year. None of this is a gray area: these are obligations with deadlines and forms.

Isn't offshore for people who evade taxes?

That association comes from an era when bank secrecy between countries was real. It no longer is: Brazil joined the global standard for automatic exchange of financial information, and banks abroad report the accounts of Brazilian residents. An offshore company set up correctly is declared in your DIRPF (Brazil's individual income tax return) and known to the Receita from day one. What it does is organize ownership and succession. What it does not do is hide anything. Anyone offering that is offering a crime, not planning.

How much do I need for it to make sense?

There is no magic number, and be wary of anyone who gives you one. What exists is a calculation: the structure has a fixed annual cost (incorporation, registered agent, local accounting), and that cost does not shrink because your wealth is smaller. For many people, international exposure through funds and ETFs in Brazil, or a simple international account in your own name, achieves the goal with no corporate structure at all. I would rather tell you that than sell you complexity.

Why does a structure help with succession?

For two practical reasons. First, assets held directly abroad by a Brazilian follow the law of the country where they are located when the holder dies. In the United States, for example, assets located there can fall into local probate and into inheritance tax rules far less favorable to non-residents than to residents. Second, when the wealth sits inside a legal entity, what is transmitted is shares, under a rule set out in a document, and not a list of accounts at different banks. The tax and legal details of this are for a tax lawyer to answer: my part is to show you that the problem exists before it becomes an estate.

Let's look at your case before talking about structure

In the first conversation I understand where your wealth is today, in which currency your expenses for the coming years are, and whether going international makes sense for you, including when the answer is that it does not.

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