Lawyer Claims Tax Reform Intensified Capital Outflow From Country and Boosted International Planning Among Brazilians and Companies With Operations or Clients Abroad.
A survey presented by tax lawyer José Andrés Lopes da Costa indicates progress in the outflow of resources from the country following the tax reform.
In an interview on the ALive program this Friday (3), he stated that individuals and companies with international profiles have been seeking structures abroad to protect assets and reorganize operations.
“The tax reform, in a nutshell, those who can, ‘hit the road’,” he said.
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Reform Boosts Resource Outflow, Says Tax Lawyer
According to Costa, the demand for wealth planning outside Brazil has continuously increased in recent years and gained momentum with the change in the tax system.
The lawyer reported that the company he founded in 2016 was created to serve about 300 clients, but today accounts for 11 thousand individuals and companies sending money abroad.
“There are 11 thousand people sending money overseas. And not just individuals. There are legal entities leaving Brazil as well,” he stated.
Still according to the tax lawyer, this movement is not limited to large conglomerates.
Freelancers, investors, and medium-sized companies that earn with contracts in other currencies are also redesigning structures.
For him, the perception of regulatory uncertainty and the prospect of increased burdens in certain segments contributed to the decision to diversify risks, keeping part of the capital outside the country.
Search for International Planning Grows
Costa stated that the demand for international planning encompasses various fronts: opening accounts abroad, establishing holdings, transferring financial assets, and corporate restructuring.
In his assessment, those with recurring income in dollars or euros have been quicker to adopt these measures.
He emphasizes that the strategy, when carried out within the law and with formal declaration to Brazilian authorities, is a means of asset organization, not tax evasion.
The lawyer’s narrative highlights that the initial step is usually assessing tax residency, followed by analyzing treaties to avoid double taxation and, finally, structuring an operation that facilitates the daily operation of the business.
Even though each case requires a specific design, gaining tax predictability and simplifying compliance obligations would be the main goals of those seeking alternatives.
Companies Transfer Operations to Neighboring Countries
Business owners with a significant client base abroad have been relocating part of their activities to nearby markets, reported the tax lawyer.
“Several legal entities that have income from abroad, that have foreign clients, are leaving Brazil and moving to Paraguay and Uruguay, which have a free trade zone, with super low contributions, to continue their activities,” he said, citing the existence of special regimes in neighboring countries.
This redesign would include everything from issuing invoices through foreign subsidiaries to changing administrative headquarters while maintaining distributed teams.
For those providing digital services, marketing, or consulting, the relocation would be operationally simpler.
On the other hand, sectors that require physical presence tend to adopt hybrid models, with part of the team in Brazil and part outside, depending on the client profile.
Declared Offshores as an Alternative
Regarding financial assets, Costa argued that for those with substantial assets, it makes more sense to structure resources in declared offshores rather than concentrating them in Brazil.
“Why keep assets in Brazil, money in Brazil, just to keep getting hit all the time? It doesn’t make sense,” he stated.
The guidance, according to him, is to choose jurisdictions with clear regulations, good governance, and stability, always observing transparency and reporting requirements.
The lawyer emphasized that for investors with diversified portfolios, international allocation seeks to reduce exposure to country risk, protect against currency volatility, and broaden access to financial products that are not available domestically.
In his view, the trend is that this practice will become more common among business families and professionals with global operations.
Stability and Client Profile Weigh in the Decision
In the tax lawyer’s view, the choice to migrate operations or assets is usually associated with the revenue profile.
Those who primarily depend on the domestic market would have less room to relocate, as “those with Brazilian clients cannot do this.”
In contrast, companies with an international client base would see more advantages in seeking economic and political stability in other markets, like those mentioned by him.
Costa argued that the predictability of rules and the competitive tax burden are decisive factors.
He added that international organization does not eliminate obligations with the Brazilian tax authorities when there is a tax residency link or income generation in the country, but it can redesign the point of taxation and the way of assessment.
The goal, he asserts, is to operate within the rules and minimize risks.
What Remains From the Lawyer’s Diagnosis
The account presented on ALive depicts a snapshot of part of the market, emphasizing the slice of taxpayers who have income and clients abroad.
Costa’s remarks suggest a gradual detachment of this audience toward more predictable structures.
Although the magnitude of this flow varies by segment, the assessment remains that the tax reform accelerated decisions that were already under consideration.
Nevertheless, the lawyer emphasized that the strategy does not serve everyone.
For those who primarily sell in Brazil, moving headquarters is unlikely to pay off.
However, for internationalized companies, the math may work out.
In this scenario, the main motivation mentioned by him is the search for regulatory simplicity, effective burden reduction, and legal security in the medium and long term.
Ultimately, the tax lawyer leaves a practical question in the air: as the new tax framework is regulated, will the domestic environment be able to provide enough predictability to retain those who today operate with clients and revenues in other currencies?


Eles com medo do país quebrar e a economia crescendo.
Continuem👍🏽
Aonde você esta vendo a economia crescendo? A única coisa que vejo é um mercado financeiro cada vez mais enforcado. Com aumento dos impostos e o repasse para o consumidor final. Isto não passa de um desgoverno total. Gastos públicos desenfreado. Inflação.