Estonian Company Run from Brazil: Tax Rules

Many Brazilian entrepreneurs form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Brazil. Brazilian income tax looks at the company and at its owner. The company side: Brazil taxes legal persons domiciled in Brazil and the branches, agencies or representations in Brazil of companies with their seat abroad. The owner side: since 2024 a Brazilian resident individual who controls a foreign entity declares its profits — every year for some entities, when they are made available for others. And there is no tax treaty between Estonia and Brazil. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Brazilian tax adviser (contador or advogado tributarista) before you form or buy the company. We read the Income Tax Regulation (Regulamento do Imposto sobre a Renda, Decree no. 9,580 of 2018) and Law no. 14,754 of 12 December 2023 on the official site of the Brazilian Presidency, planalto.gov.br, and the list of Estonia's tax treaties published by the Estonian Ministry of Finance, on 21 October 2026; the English wording below is our translation.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Brazil: the company side

Who is taxed as a legal person. The regulation counts as legal persons the private-law legal persons domiciled in Brazil, whatever their purpose, nationality or shareholders; the branches, agencies or representations in Brazil of legal persons with their seat abroad; and principals domiciled abroad for the results of operations carried out by their agents in Brazil (Income Tax Regulation, article 159).
Regardless of formal constitution. The rule applies whether or not the legal person is regularly constituted; it is enough that it forms an economic or professional unit (article 158(1)).

An Estonian OÜ is a legal person with its seat in Estonia. Whether running it from Brazil makes it — or a part of its activity — taxable in Brazil under these rules depends on the facts: where the business is in fact carried on and who acts for it in Brazil. Your Brazilian tax adviser answers that with the facts of your case.

In Brazil: the owner side

Income from a controlled entity abroad. A Brazilian resident individual declares income from capital invested abroad — including profits and dividends of controlled entities — separately in the annual return, taxed at 15% on the annual amount without deductions (Law no. 14,754/2023, article 2(1)).
What "controlled" means. Companies and other entities abroad are controlled where the individual, alone or with others, has rights that ensure preponderance in the decisions or the power to elect or remove most of the managers, or holds, alone or with related persons, more than 50% of the capital or of the rights to profits or assets (article 5(1)).
Taxed every year for some. The profits of a controlled entity are taxed on 31 December of each year if it is located in a country with favoured taxation or benefits from a privileged tax regime under articles 24 and 24-A of Law no. 9,430 of 1996, or if its own active income is less than 60% of its total income (article 5, caput and (5)). Royalties, interest, dividends, rents, financial investments and similar items do not count as active income (article 5(6)).
When made available for the others. The profits of a controlled entity outside those cases are taxed when they are actually made available to the individual — paid, credited, delivered, used or remitted (article 6).

No tax treaty between Estonia and Brazil

Brazil is not on the list of Estonia's tax treaties published by the Estonian Ministry of Finance. So no treaty decides which country a company resident in both is resident of, and no treaty limits the tax either country charges on dividends or management fees. Each country applies its own law; whether and how double taxation is relieved then depends on each country's domestic rules — a question for your Brazilian tax adviser. We do not give that ruling.

What to decide before you form or buy the company

Where the business is carried on, and who acts for it in Brazil. These are the facts the Brazilian rules on legal persons and representations look at.
What the company earns. The share of active income decides whether its profits are taxed in Brazil every year or only when made available.
How profits reach you. Dividends and other payments are declared in your annual return.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Brazilian tax returns and Brazilian tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Brazilian tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Brazil if I run it from Brazil?

Parts of it can be. Brazil taxes legal persons domiciled in Brazil and the branches, agencies or representations in Brazil of companies seated abroad (Income Tax Regulation, article 159). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). A Brazilian resident individual who controls the company declares its profits at 15% — every year if its own active income is under 60% of its total income or it is in a favoured-tax country, otherwise when the profits are made available (Law no. 14,754/2023, articles 2, 5 and 6). There is no tax treaty between Estonia and Brazil. Ask a Brazilian tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Brazil: what is taxed where