The Dispute Over Silvio Santos’ Inheritance Involves Billion-Dollar Amounts, Tax Questions, and a Judicial Expertise That Promises to Detail Assets in Brazil and Abroad.
The São Paulo Court has ordered the conduct of an independent expertise to detail assets, accounts, and companies linked to Silvio Santos’ inheritance, who passed away in 2024.
The report will serve as the basis for determining tax collection on part of the assets held abroad, estimated at hundreds of millions of reais.
This measure responds to a lawsuit filed by the widow, Íris Abravanel, and the six daughters of the host, who contest the tax requirement to release funds deposited outside Brazil.
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The case is being processed under secrecy at the São Paulo Court of Justice, but recent decisions have made some figures from the estate public.
Tax on Values Abroad
The focus of the dispute is an amount of approximately R$ 429 million linked to the company Daparris Corp Ltd, based in the Bahamas, a tax haven in the Caribbean.
These funds are part of Silvio Santos’ estate and are blocked while the application of ITCMD, the Inheritance and Donation Tax, is being discussed.
According to the São Paulo government, the tax owed on this portion amounts to about R$ 17 million, a value that has already been subject to preliminary decisions for deposit in court and temporary suspension of collection.
The defense of the Abravanel family argues that there should be no state taxation on these resources as they are entirely abroad.
The argument is based on the understanding of the Federal Supreme Court that states cannot collect ITCMD on inheritances of assets located outside the country without a federal complementary law.
Also in the tax realm, the heirs contest calculations made by the São Paulo Treasury Department.
According to the lawsuit, there was an increase of about R$ 47 million in the value considered for the transfer of assets from five companies linked to the group, which, in the family’s view, inflated the calculation base for the tax.
Expertise on the Assets of R$ 6.4 Billion

Documents submitted in the case indicate that Silvio Santos’ estate reaches about R$ 6.4 billion, distributed among cash, financial assets, equity interests, and real estate in Brazil and abroad.
This amount far exceeds previous estimates regarding the host’s fortune.
The expertise determined by the Court will examine the entire asset structure of the group, including business entities linked to the host.
The goal is to assess the net worth of these companies, the location of the assets, and the form of corporate organization.
The work will be conducted by an expert appointed by the court and funded by the family itself, with a deadline of about 60 days for the report to be presented.
This report should point out the actual values of the inheritance, indicate which assets are in Brazil and which remain in foreign jurisdictions, and show how each portion relates to the calculation of ITCMD.
Based on this information, it will be up to the Court of Justice to determine whether the tax collection will be maintained and to what extent.
Debts Left and Use of Blocked Values
In the records, the heirs have communicated that they intend to use part of the resources held abroad to settle a debt of about R$ 10 million, related to a loan taken by Silvio Santos before his death.
However, payment depends on the release of the funds currently tied to the tax dispute.
As the impasse continues, the family is trying to secure access to the money abroad without the immediate collection of the contested tax.
In previous statements, the business group linked to the host stated that all assets were declared to tax authorities and that the dispute is limited to the application of tax legislation.
Debate on Taxation of Inheritances Abroad
The controversy over Silvio Santos’ inheritance occurs amid a broader debate about taxation of inherited assets outside the country.
In a decision of general repercussion, the Supreme Court deemed unconstitutional state laws that provided for the collection of ITCMD on inheritances abroad without a federal complementary law.
In the case involving the Abravanel family, the State of São Paulo argues that the tax is owed and that the collection is based on local legislation.
Meanwhile, the family’s defense invokes the understanding established by the Supreme Court and states that, without specific national regulation, it would not be possible to demand ITCMD on values kept in the Bahamas.
The outcome of the case is being monitored by tax experts and heirs who possess assets outside the country.
Decisions of this nature often guide similar litigation and influence how large fortunes structure their succession planning.
The expertise is likely to be a central piece in this definition, establishing precisely how much, where, and in what way the fortune left by the host is organized.

eis aí mais uma prova de que rico não gosta mesmo de pagar impostos. ninguém em sã consciencia gosta de ser espoliado, mas se está na Lei. mas por que só os assalariados pagam impostos na fonte, e após entregar a declaração, o “contribuinte” ainda tem que pagar um “resíduozinho”(imposto devido) ao leão????
ABSURDO! ESSE GOVERNO COMUNISTA QUERER ABOCANHAR PARTE DA FORTUNA DA FAMILIA ABRAVANEL, DEIXADA PELO SAUDOSO SILVIO SANTOS…