We structure offshore companies, trusts and holding companies for business-owning families that need tax efficiency, orderly succession and full compliance, in Brazil and abroad.
Each entry leads to what the law requires, the most common questions and the articles on the subject.
Review of offshore companies and trusts under Law 14,754/2023, reporting in the income tax return and DCBE, and banking feasibility of the structure.
See the path →ii.Family holding company, gifts of shares with retained usufruct, will and family protocol, with the inheritance tax (ITCMD) calculation.
See the path →iii.Departure notice and definitive departure return, tax residence and the treatment of assets that stay in Brazil.
See the path →iv.Corporate reorganisation, shareholders' agreement, due diligence and preparation of personal wealth before the liquidity event.
See the path →Integrated regulatory compliance for companies that need legal certainty in data protection and governance. This practice is led by Deborah do Valle Montenegro, with attention to regulated sectors such as healthcare and construction, among others.
About this practice →Cases of business-owning families, little-known laws and changes in Brazilian legislation, in plain language.




We map assets, existing structures, tax residence and the family's goals. We identify risks, hidden liabilities and opportunities before proposing anything.
We design the solution (holding company, trust, offshore company, will, or a combination) with a tax calculation memo and an implementation schedule for each jurisdiction.
We implement with local partners in more than 20 jurisdictions and remain responsible for annual compliance: filings, minutes, substance and legislative reviews.
Yes. Structures abroad are lawful as long as they are reported to the Brazilian Federal Revenue and to the Central Bank (DCBE, when applicable). The irregularity lies in the omission, not in the structure. Our work is to make sure everything is reported and documented.
Profits of controlled foreign companies are now taxed annually at 15%, even when not distributed, and trusts received their own tax treatment. Structures set up before 2024 often need to be reviewed.
In many cases, yes. Gifting shares with retained usufruct can reduce probate costs and inheritance tax (ITCMD). The outcome depends on the state, on the composition of the assets and on the family. The analysis is always individual.
A private meeting, in person in Goiânia or by video call, in which we review your situation and goals. It results in an assessment and the structuring alternatives for your case, all under legal professional privilege.
Yes. Assets and rights held abroad go into the annual Brazilian income tax return regardless of value. Anyone holding USD 1 million or more on 31 December also files the DCBE with the Central Bank. Omission leads to fines and may constitute a criminal offence. Regularising is always the cheaper path.
Yes. Anyone leaving the country permanently must formalise their tax exit with the departure notice and the definitive departure return. Without it, the Federal Revenue continues to treat you as a resident, taxable in Brazil on worldwide income even while living abroad. It is one of the most common and most expensive mistakes we see.
An initial assessment meeting, private and with no ready-made model: a technical reading of your case and of the alternatives for your wealth.