IRPF 2026 and International Taxation: What Brazilians Abroad Need to Know

IRPF 2026: Rules for Brazilians with Income and Assets Abroad

Brazil’s Federal Revenue Service (Receita Federal) published, on March 16, 2026, Normative Instruction No. 2.312, establishing the rules for the Annual Income Tax Return (Declaração de Ajuste Anual) for fiscal year 2026, base year 2025. For Brazilians living abroad, digital nomads, or those with international investments and asset structures, this return involves nuances that deserve special attention.

This article analyzes the main points of the new normative instruction from an international taxation perspective, focusing on the practical impacts for those who maintain tax residency in Brazil and have income or assets outside the country.

1. Filing Deadlines and Submission Channels

The return may be filed between March 23 and May 29, 2026, through the Declaration Generator Program (PGD), available from March 20, or via the “Meu Imposto de Renda” (My Income Tax) service, accessible through the gov.br portal or the Federal Revenue app (requiring a Gold or Silver gov.br account).

It is important to note that the “Meu Imposto de Renda” service has specific restrictions for certain situations involving foreign assets, as discussed below. Therefore, those with more complex international structures will, in many cases, need to use the PGD exclusively.

2. Who Is Required to File: Focus on International Scenarios

IN No. 2.312/2026 maintains, with some value adjustments, the mandatory filing criteria. The main points of attention for those with international connections are:

•       Taxable income above R$ 35,584.00: new threshold, updated from the previous year’s R$ 33,888.00. Includes income received from abroad that is taxable in Brazil.

•       Exempt or withheld-at-source income above R$ 200,000.00: maintained. Relevant for those receiving foreign dividends or holding financial investments with significant returns.

•       Assets exceeding R$ 800,000.00 as of 12/31/2025: maintained. Sum of all assets and rights, including those abroad.

•       Resident status: those who became tax residents of Brazil in any month of 2025 and remained so as of 12/31/2025.

•       Trust ownership: those who were holders of a trust or similar contract governed by foreign law as of 12/31/2025 (articles 10 to 13 of Law No. 14,754/2023).

•       Controlled entities abroad (offshores): those who opted for the tax transparency regime or hold interests in controlled entities abroad (articles 5 to 6-A and 8 of Law No. 14,754/2023).

•       Foreign financial investments: those who earned income or intend to offset losses from foreign financial investments (articles 2 to 4 and 9 of Law No. 14,754/2023).

•       Profits from foreign entities: those who earned profits or dividends from foreign entities (articles 2 and 5 to 6-A of Law No. 14,754/2023).

3. Law No. 14,754/2023 in Its Second Year: Consolidation of the Annual 15% Tax Rate

IRPF 2026 marks the second fiscal year in which the regime introduced by Law No. 14,754/2023 (known as the “Offshore Law”) fully applies. Its main established features are:

•       Unified annual taxation: income from foreign financial investments and profits from controlled entities are declared and taxed directly in the Annual Adjustment Return, at a flat rate of 15%, separately from other income.

•       End of monthly assessment: it is no longer necessary to fill out the Carnê-Leão or GCAP for foreign investments. All assessment is done annually within the return itself.

•       Loss offsetting: losses from foreign financial investments may be offset against gains of the same nature in the same period or in subsequent periods.

•       Tax transparency: taxpayers with controlled entities abroad may opt to declare the entity’s assets and rights as if they were held directly by the individual.

•       Trusts: income and capital gains from assets and rights held in trust are considered earned by the holder, subject to taxation under the applicable rules.

4. Restrictions on “Meu Imposto de Renda” for International Situations

Article 5 of IN No. 2.312/2026 expressly restricts the use of the “Meu Imposto de Renda” service in several situations common to taxpayers with international assets. Among them:

•       Capital gains from the sale of assets, rights, and financial investments abroad.

•       Capital gains from the sale, write-off, or liquidation of investments in controlled entities abroad.

•       Capital gains from the sale of foreign currency in cash exceeding US$ 5,000.00 in the calendar year.

•       Capital gains from non-interest-bearing deposits in checking accounts or credit/debit cards abroad transferred to Brazil or held in unauthorized institutions.

In practice, most taxpayers with more complex international tax situations will need to use the PGD to prepare their return.

5. Pre-Filled Return Updates for Foreign Assets

One of the main innovations announced by the Federal Revenue for IRPF 2026 is the enhancement of the pre-filled return, which now includes e-Social data on domestic employees, information on income tax withheld at source on variable income, and recovery of payment DARFs. Data on foreign investments via e-Financeira and information from Receita Saúde, with over 30 million receipts registered in 2025, have also been included.

Although the pre-filled return significantly facilitates the process, it is essential that taxpayers verify all imported data, especially regarding international assets, which may require exchange rate conversion adjustments or reclassification.

6. Refunds in 4 Batches and Priorities

IRPF 2026 refunds will be paid in four batches, reduced from the usual five. The dates are: May 29, June 30, July 31, and August 31. The Federal Revenue estimates that 80% of taxpayers entitled to refunds will receive their amounts by June 30.

The priority order follows legal criteria (elderly, disabled individuals, teachers), with an additional incentive: those who use the pre-filled return combined with Pix CPF refund will have priority over other taxpayers.

7. Automatic Refund — New Feature for Calendar Year 2024

The Federal Revenue also announced a special automatic refund batch for taxpayers who did not file returns for calendar year 2024 because they were not required to, but had amounts withheld at source with refund entitlement. An estimated 4 million taxpayers are expected to benefit from this measure, with an average refund of R$ 125.

The automatic return will be generated starting June 15, 2026, with credits from July 15 onward, for taxpayers with a Pix key linked to their CPF and refunds of up to R$ 1,000.00.

8. Declaration of Assets Abroad

Article 11 of the IN requires taxpayers to list all assets and rights constituting their estate as of 12/31/2024 and 12/31/2025, in Brazil or abroad. Assets held in trust must be reported at acquisition cost. Exemptions apply to bank account balances up to R$ 140.00, movable property below R$ 5,000.00 (except vehicles), and shares below R$ 1,000.00.

9. Late Filing Penalty and Sanctions

The late filing penalty is 1% per month on the tax due, with a minimum of R$ 165.74 and a maximum of 20% of the tax. The Federal Revenue reinforced that late filing does not entail more severe consequences such as banking restrictions or criminal indictment, combating misinformation that circulated in the previous year.

10. Practical Recommendations

For Brazilians abroad, digital nomads, and taxpayers with international asset structures, the following recommendations are particularly relevant at this time:

1.     Organize your documents in advance: foreign account statements, income reports, balance sheets of controlled entities, and proof of taxes paid abroad.

2.     Check whether you need to use the PGD: most more complex international situations are restricted from “Meu Imposto de Renda.”

3.     Pay attention to exchange rate conversion: use the closing selling rate published by the Central Bank on the date of the triggering event.

4.     Use the pre-filled return with caution: review all imported data, especially international assets.

5.     Seek specialized guidance: international taxation involves nuances that require specific technical knowledge to avoid inconsistencies and risks of falling into the fine mesh (malha fina).

Note: This article is for informational and educational purposes only, based on Normative Instruction RFB No. 2.312/2026 and Law No. 14,754/2023, and does not constitute legal or tax advice for specific cases. For personalized guidance, consult a specialized professional.

If you are interested in hiring professional legal services related to international tax planning, we are a firm specializing in this field. Please contact us via e-mail: contato@trpuppioadvocacia.com.br or via WhatsApp.