All questions

Tax residence and fiscal domicile

i Corporate residence

A corporation is considered as resident in Brazil if it has been incorporated in Brazil. Its tax domicile is where its head office is located.

ii Branch or permanent establishment

No foreign corporation may carry out permanent activities in Brazil other than through a registered subsidiary, branch, or permanent establishment. A branch is considered to be a permanent establishment as it is an agent who has powers to bind an overseas principal contractually. Each tax treaty should be consulted for further details and definitions of permanent establishment, but in Brazil a branch depends upon public authorisations and the qualification as a permanent establishment will be treated as irregular activity in Brazil if it is not registered as a branch.