Tax residence in Brazil for Indian taxpayers

Brazil has no single day test. You become resident from the day of arrival if you come to live permanently or on a temporary visa to work under an employment contract; on another temporary visa, from the day you reach 184 days (consecutive or not) within 12 months of arrival. Brazil splits the year, and anyone who leaves without the notice of definitive departure stays resident for the first 12 months abroad. India counts your days over its tax year (1 April – 31 March). Dual residence is settled by Art. 4(2) of the India–Brazil Convention of 1988; its 2022 Protocol applies in India from tax year 2026-27, with the same tie-breaker for individuals.

Check your status: India and Brazil

Free, no sign-up, about 3 minutes. Conclusion under Indian income-tax law, compared with the law of Brazil and the tax treaty.

When Brazil treats you as a tax resident

Brazil has no single day threshold for everyone: residence depends on whether you live in Brazil permanently, on the visa you entered with and its purpose, and for temporary stays on 184 days within 12 months. Residence begins on a specific date (the day of arrival or the 184th day) and ends on the day of definitive departure, so the year is split into periods.

For temporary stays the threshold is 184 days (more than 183) of presence, consecutive or not, within 12 months from the day of arrival. If 184 days are not reached within 12 months, a new 12-month period starts with the next entry. You become resident from the day you reach 184 days — not from the start of the year.

Definitive departure with the notice (Comunicação de Saída Definitiva do País) makes you a non-resident from the day of departure. Without the notice, as with a temporary departure, you remain resident for the first 12 consecutive months abroad and become a non-resident from the following day.

You live in Brazil permanently — you are a Brazilian tax resident (art. 2 IN SRF nº 208/2002) and pay personal income tax (IRPF) on worldwide income. A foreigner with a permanent visa, or a Brazilian citizen who has come back to live for good, is resident from the day of arrival. Permanent residence is assessed on the facts: where you live and where your family, work and property are.
You entered with a temporary visa to work under an employment contract in Brazil (or signed such a contract during your stay) — you are a Brazilian tax resident from the day of arrival (from the day of signing the contract), whatever the number of days (art. 2 IN SRF nº 208/2002, art. 17 RIR/2018), and pay IRPF on worldwide income.
You stayed in Brazil for more than 183 days (consecutive or not) within 12 months — you are a Brazilian tax resident from the day you reached 184 days (art. 2 IN SRF nº 208/2002; under art. 17 II RIR/2018, taxation as a resident covers taxable events from the day after that period is completed); from that date Brazil taxes your worldwide income, and before it only income from Brazilian sources, as income of a non-resident.
You work abroad as an employee of a Brazilian government office — you remain a Brazilian tax resident whatever the number of days spent in Brazil (art. 2 IN SRF nº 208/2002, arts. 15, 37 RIR/2018). Employees of State-owned companies and locally hired embassy staff are not covered.
You left Brazil permanently in the selected year — until the day of departure you were a Brazilian tax resident, and from the day of departure you are a non-resident, provided you filed the notice of definitive departure by the end of February of the following year. A Declaração de Saída Definitiva do País is filed for the period of residence; Brazilian-source income after departure is taxed by withholding at source (art. 14 RIR/2018).
You left without the notice of definitive departure, or temporarily, and 12 consecutive months abroad have not yet passed — in the selected year you remain a Brazilian tax resident and pay IRPF on worldwide income (art. 2 IN SRF nº 208/2002, art. 14 § 3 RIR/2018). If you left for good, file the notice of definitive departure by the end of February of the following year — you will then be a non-resident from the day of departure.
You left without the notice of definitive departure, or temporarily, and 12 consecutive months abroad were completed in the selected year — until that day you were a Brazilian tax resident, and from the following day you are a non-resident (art. 3 IN SRF nº 208/2002, art. 14 § 3 RIR/2018). File the Comunicação de Saída Definitiva do País by the last day of February of the following year and, for the period of residence, the Declaração de Saída Definitiva do País (P&R IRPF 2026, question 117).

When you are a nonresident

You left Brazil permanently before the selected year began and filed the notice of definitive departure — you are not a Brazilian tax resident (art. 3 IN SRF nº 208/2002). Brazil taxes only Brazilian-source income, by withholding at source (pay and services — 25%, most other income — 15%, dividends from 2026 — 10%). If you have come back intending to live in Brazil, you are resident again from the day of arrival.
You left without the notice, or temporarily, and 12 consecutive months abroad were completed before the selected year began — you are not a Brazilian tax resident (art. 3 IN SRF nº 208/2002). Brazil taxes only Brazilian-source income, by withholding at source. If you did not file the Declaração de Saída Definitiva do País for the year of departure, you can still do so later (within five years) — with a penalty.
You came to Brazil temporarily and did not reach 184 days within 12 months, and you have no employment contract in Brazil, permanent visa or residence permit — you are not a Brazilian tax resident (art. 3 IN SRF nº 208/2002). Brazil taxes only Brazilian-source income, by withholding at source (pay and services — 25%, most other income — 15%, dividends from 2026 — 10%).
You neither lived nor stayed in Brazil — you are not a Brazilian tax resident (art. 3 IN SRF nº 208/2002). Brazil may tax only Brazilian-source income, by withholding at source.

Where the rules of Brazil clash with Indian tax rules

Collision: resident of both India and Brazil. Brazil treats you as resident — through permanent residence, a temporary visa to work under an employment contract, 184 days within 12 months of arrival, or the first 12 months after leaving without the notice of definitive departure. India treats you as resident for its tax year with 182 days in India, or 60 days plus 365 days in the four preceding years. Art. 4(2) of the Convention decides: a permanent home in only one country — resident of that country; a home in both — centre of vital interests; then habitual abode, nationality and mutual agreement of the competent authorities (Art. 25). Double tax is relieved by credit in both countries (Art. 23).

What else to know

Which treaty applies: the India–Brazil Convention of 1988, amended in 2022. Between India and Brazil the Convention signed at New Delhi on 26 April 1988 applies; it has been in force since 11 March 1992. The Protocol of 15 October 2013 replaced only the exchange-of-information article. The Protocol of 24 August 2022 (in force 18 October 2025) rewrote much of the Convention: it has effect in India for income of previous years beginning on or after 1 April 2026 (tax year 2026-27 onwards) and in Brazil from 1 January 2026, so for India's year 2025-26 the original text still applies. The tie-breaker for individuals is the same in both texts — Art. 4(2): permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. Under the amended text: pay — Art. 15(2) (183 days in any twelve-month period); independent services — Art. 14 (fixed base or 183 days); fees for technical services — new Art. 12-A (10%); pensions — Art. 18; government service — Art. 19; relief — Art. 23 (credit in both countries); mutual agreement — Art. 25 (three years); limitation on benefits — new Art. 26-A. Brazil has signed but not ratified the MLI, so the MLI does not modify the Convention in 2026.
Brazil counts 184 days within 12 months from arrival and splits the year. For temporary stays Brazil counts days (consecutive or not) within 12 months from the day of arrival, not in the calendar year; if 184 days are not reached, a new 12-month period starts with the next entry. You become resident from the 184th day — a stay from July to February can make you resident only in the following year; with a temporary visa to work under an employment contract — from the day of arrival. India counts your days in India over its tax year (1 April – 31 March) and decides your status for the whole year, so the two results may not coincide. Keep a day-by-day record.
Year of moving: Brazil splits the year, India does not. Brazilian residence begins on a specific date (the day of arrival or the 184th day) and ends on the day of definitive departure; for the rest of the year Brazil taxes only Brazilian-source income. India decides your residential status for the whole tax year (1 April – 31 March) and does not split it. Where both countries treat you as resident for the same period, Art. 4(2) of the Convention decides; remaining double taxation can be taken to the mutual agreement procedure within three years (Art. 25).
Leaving Brazil: the notice by the end of February. If you leave Brazil for good — for example to move to India — file the notice of definitive departure (Comunicação de Saída Definitiva do País) by the last day of February of the following year: you are then a non-resident from the day of departure, and you file the Declaração de Saída Definitiva do País for the period of residence. Without the notice Brazil treats you as resident for the first 12 months abroad and taxes your worldwide income for that time — this can overlap with Indian residence, and Art. 4(2) of the Convention then decides. Tell Brazilian payers of income (bank, employer, pension fund) about your departure so that they withhold at non-resident rates.
Working in Brazil while resident in India: the 183-day rule (Art. 15(2)). Pay for work performed in Brazil is Brazilian-source income; for non-residents of Brazil 25% is withheld. If you are a resident of India under the Convention, Brazil does not tax it when all conditions of Art. 15(2) are met: not more than 183 days in Brazil in any twelve-month period, an employer not resident in Brazil, and pay not borne by the employer's permanent establishment in Brazil (for India's year 2025-26 the original text counts the 183 days in the fiscal year concerned). Self-employed: Art. 14 — Brazil may tax the income if you have a fixed base regularly available there or stay 183 days or more in any twelve-month period commencing or ending in the fiscal year. A temporary visa to work under a Brazilian employment contract makes you resident in Brazil from the day of arrival. India credits the Brazilian tax (Art. 23); claim it with Form No. 44 (rule 76 of the Income-tax Rules, 2026).
How India and Brazil relieve double taxation. If India is your state of residence, India deducts from Indian tax the income tax paid in Brazil on income that Brazil may tax under the Convention, up to the Indian tax attributable to that income (Art. 23 as replaced by the 2022 Protocol); claim it with Form No. 44 and proof of the Brazilian tax (rule 76 of the Income-tax Rules, 2026). If Brazil is your state of residence, Brazil deducts the income tax paid in India in the same way (Art. 23; art. 115 RIR/2018) — without a treaty Brazil allows a credit only where the source country grants reciprocity, so the Convention matters here. Exempt income may be taken into account for the rate on other income. The original Art. 23, which India still applies to its year 2025-26, also deemed interest and royalties taxed at 25%. Tax charged beyond what the Convention allows can be taken to the mutual agreement procedure within three years (Art. 25).
Brazilian withholding on a resident of India: treaty limits and certificates. As a resident of India you can claim the Convention's limits on Brazilian withholding (amended text, applied in Brazil from 1 January 2026): dividends 15%, or 10% for a company holding at least 20% for 365 days; interest 15%, or 10% on bank loans of at least five years; royalties 10%, or 15% for trademarks; fees for technical services 10% (Art. 12-A). Brazil's domestic 10% on dividends paid abroad from 2026 is already within the treaty limit. The new Art. 26-A can deny these benefits in abusive arrangements. Foreign tax authorities and payers usually ask for proof of Indian residence before applying a treaty: apply for an Indian tax residency certificate in Form No. 42 on the e-filing portal; it is issued in Form No. 43. To claim the Convention in India as a resident of Brazil, give the Indian payer a certificate of residence from Receita Federal and the prescribed information (s. 159(8)). You need a CPF to deal with Brazil's tax authority.
Pensions and government service. Pensions for past employment are taxable in your state of residence, but the country where the payer (or a permanent establishment bearing them) is resident may tax them too (Art. 18(1)–(2)); the state of residence then gives credit (Art. 23). Payments under a public social security scheme are taxable only in the country that pays them (Art. 18(3)): a pension from Brazil's public scheme only in Brazil. Under Brazilian law pensions paid to non-residents are taxed at the progressive scale, not at 25%, since the Supreme Federal Court's ruling (Tema 1.174). Government salaries and pensions are taxed by the paying country, with exceptions for residents and nationals of the other country (Art. 19).
Indian income of a Brazilian resident: monthly payment and 15% on investments. A Brazilian resident declares income from abroad even if it is not remitted to Brazil. Pay, pensions or rents from India are paid monthly (carnê-leão) at the progressive scale and included in the annual return. Interest, dividends and gains from financial investments in India are taxed at 15% in the annual return (Lei nº 14.754/2023); profits of a controlled foreign company in a favoured jurisdiction or with mainly passive income are taxed every year, even without a distribution. Indian income tax is deducted only up to the Brazilian tax on that income (Art. 23 of the Convention; art. 115 RIR/2018); for income under Lei nº 14.754/2023 an unused credit cannot be carried to other years.
The 2026 reform: no tax up to R$ 5,000 and a minimum tax on high incomes. From 2026 a resident's income tax is reduced so that it is zero for taxable income up to R$ 5,000 a month (the reduction phases out up to R$ 7,350). At the same time a minimum tax applies to total income above R$ 600,000 a year — up to 10% at R$ 1,200,000 or more, counting dividends and other exempt income; dividends above R$ 50,000 a month from one company are subject to 10% withholding. Dividends paid to non-residents are taxed at 10% from 2026.
Social security: India–Brazil agreement. Brazil is on EPFO's list of countries with which India's social security agreements operate. An employee posted from India to Brazil can stay in the Indian system with a certificate of coverage from EPFO and avoid Brazilian contributions; periods in both countries also count toward pension eligibility. Check the posting limit in the agreement and apply to EPFO before the posting starts.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Government of the Federative Republic of Brazil and the Government of the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at New Delhi on 26 April 1988, as amended by the Protocols signed at Brasília on 15 October 2013 and 24 August 2022. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in Brazil

Receita Federal: Brazil's federal tax authority
IRPF: personal income tax; residents pay it on worldwide income
carnê-leão: monthly payment of tax on income from abroad on which no tax was withheld in Brazil
Comunicação de Saída Definitiva do País: notice of definitive departure: filed by the last day of February of the following year, it makes you a non-resident from the day of departure
Declaração de Saída Definitiva do País: return for the period of residence in the year of definitive departure
CPF: taxpayer number needed for dealings with Brazil's tax authority

Questions

Which DTAA applies between India and Brazil?

The Convention signed at New Delhi on 26 April 1988, in force since 11 March 1992. The Protocol of 24 August 2022 applies in India to income of previous years beginning on or after 1 April 2026 and in Brazil from 1 January 2026; for India's year 2025-26 the original text applies. The tie-breaker for individuals in Art. 4(2) is the same in both texts.

How does Brazil count 184 days?

For temporary stays Brazil counts days (consecutive or not) within 12 months from the day of arrival, not in the calendar year; if 184 days are not reached, a new 12-month period starts with the next entry. You become resident from the 184th day; with a temporary visa to work under an employment contract, from the day of arrival.

How is double taxation relieved between India and Brazil?

Both countries give a credit under Art. 23: the state of residence deducts the tax paid in the other country, up to its own tax on that income. As an Indian resident you claim it with Form No. 44. A pension from Brazil's public social security scheme is taxable only in Brazil (Art. 18(3)).

Sources

Legislation and official guidance

art. 2 IN SRF nº 208/2002 (residente no Brasil) — A Brazilian resident is a person who: lives permanently in Brazil; left to work as an employee of Brazilian government offices abroad; entered with a permanent visa — from the day of arrival; entered with a temporary visa to work under an employment contract (or as a scholarship doctor of the Mais Médicos programme) — from the day of arrival; entered with another temporary visa — from the day 184 days of stay (consecutive or not) are reached within 12 months, or from the day of obtaining a permanent visa or an employment contract if that happens earlier; a Brazilian citizen who had non-resident status and returned intending to stay — from the day of arrival; a person who left temporarily or permanently without filing the notice of definitive departure — during the first 12 consecutive months of absence.
art. 3 IN SRF nº 208/2002 (não residente) — A non-resident is a person who does not live permanently in Brazil and does not fall within art. 2; a person leaving permanently — from the day of departure (the notice of definitive departure is mandatory); a person who left temporarily — from the day after completing 12 consecutive months abroad; a person who entered with a temporary visa and stays up to 183 days (consecutive or not) within a 12-month period; an employee of a foreign government office in Brazil. If 184 days are not reached within 12 months, a new 12-month period is counted from the next entry.
arts. 16–17 RIR/2018 (Decreto nº 9.580/2018); art. 12 Lei nº 9.718/1998 — A person with a permanent visa is taxed as a resident from the day of arrival (art. 16). A person with a temporary visa — as a resident from the day of arrival if he or she came to work under an employment contract, or from the day after completing a stay of more than 183 days (consecutive or not) within a 12-month period; until then his or her income is taxed as income of a non-resident (art. 17).
art. 14 RIR/2018 (Lei nº 3.470/1958, art. 17) — A resident who leaves permanently during a calendar year files the Declaração de Saída Definitiva do País for income from 1 January to the day before departure; income after departure is taxed by withholding at source as income of a non-resident. Anyone who left without this return is taxed as a resident for the first 12 months of absence, and as a non-resident from the 13th month.
arts. 9, 11, 11-A IN SRF nº 208/2002; art. 16 IN RFB nº 2.312/2026 (Perguntas e Respostas IRPF 2026, questions 114–126) — The notice of definitive departure (Comunicação de Saída Definitiva do País) is filed by the last day of February of the following year — it cannot be filed after that deadline; the Declaração de Saída Definitiva do País — by the annual return deadline (for 2025 departures — by 29 May 2026), and the tax is paid in a single instalment by the same date. The penalty for a late return is R$ 165.74 or 1% of the tax per month, up to 20%. A former resident must inform all Brazilian payers of income of the date of departure.
art. 47 (VII), arts. 118–120 RIR/2018; arts. 2–6 Lei nº 14.754/2023 — A resident is taxed on income received abroad whether or not it is remitted to Brazil. Pay, pensions and rents from abroad — a monthly mandatory payment (carnê-leão) at the progressive scale, taken into account in the annual return. Income from financial investments abroad and dividends of foreign companies — 15% in the annual return (since 2024); profits of a controlled foreign company in a favoured tax jurisdiction or with active income below 60% — each year on 31 December.
arts. 15, 37 RIR/2018 — Residents who work abroad for Brazilian government offices and are paid in foreign currency are taxed as residents; 25% of the amount received is included in the tax base.
arts. 741, 744–746, 760, 763, 765, 767 RIR/2018; art. 7 Lei nº 9.779/1999 — Non-residents' Brazilian-source income is taxed at source: 25% — pay and other income from work and services (art. 746); 15% — the general rate (art. 744), interest (art. 760), rent from real property in Brazil net of documented expenses (art. 763), technical and administrative services (art. 765), royalties (art. 767); 25% — for residents of favoured tax jurisdictions; capital gains on property in Brazil — at the rates for residents, 15–22.5% (art. 745).
art. 10 §§ 4–5, art. 10-A Lei nº 9.249/1995 (as amended by Lei nº 15.270/2025) — From 1 Jan 2026, profits and dividends paid abroad are subject to 10% withholding at source (except profits for periods up to and including 2025 whose distribution was approved by 31 Dec 2025); at the recipient's option a credit is possible if the company's effective tax rate plus these 10% exceeds the nominal rate (as a rule 34%).
Convention between the Government of the Federative Republic of Brazil and the Government of the Republic of India (New Delhi, 26 Apr 1988; Decreto nº 510/1992), as amended by the Protocols of 15 Oct 2013 (Decreto nº 9.219/2017) and 24 Aug 2022 (Decreto nº 12.667/2025) — In force 11 Mar 1992 (Decreto nº 510/1992). The 2013 Protocol (in force 6 Aug 2017) replaced Art. 26 (exchange of information) only. The 2022 Protocol (in force 18 Oct 2025) amended, among others, Arts. 2–5, 10–15, 17, 19(2), 23 and 25(1) and added Arts. 12-A and 26-A and a saving clause in Art. 1(2); it has effect in Brazil for amounts paid and taxable years from 1 Jan 2026 and in India for income of previous years beginning on or after 1 Apr 2026 (Protocol, Art. 22(2)). Portuguese, Hindi and English texts are authentic; the English text prevails.
Art. 4(2) of the Brazil–India Convention (as replaced by the 2022 Protocol) — Dual-resident individual: deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available in both States, of the State with which his personal and economic relations are closer (centre of vital interests); if that State cannot be determined, or if he has no permanent home available in either State, of the State in which he has an habitual abode; if he has an habitual abode in both States or in neither, of the State of which he is a national; if he is a national of both States or of neither, the competent authorities settle the question by mutual agreement. The original Art. 4(2) of 1988, which India applies to the previous year 1 April 2025 – 31 March 2026, has the same sequence.
Income-tax Act, 2025, s. 159 — The Central Government may enter into agreements for relief from double taxation and avoidance of double taxation; where an agreement applies, the Act applies only to the extent more beneficial to the assessee (s. 159(4)). A non-resident may claim treaty relief only with a certificate of residence from the other country's government and the prescribed documents and information (s. 159(8)).
Income-tax Act, 2025, s. 6(1)–(2) — Residential status is determined for each tax year. An individual is resident in India in a tax year if in India for 182 days or more in that year, or for 60 days or more in that year and 365 days or more in the four years preceding it.
Art. 23 of the Brazil–India Convention — As replaced by the 2022 Protocol: each State deducts the income tax paid in the other State, limited to its own tax attributable to that income (except where the other State taxes only because the income is also income of its resident); exempt income may be taken into account for the rate (Art. 23(1)–(2)). The original Art. 23 (still applied by India to the previous year 2025-26) also deemed interest and royalties taxed at 25%.
Art. 25 (mutual agreement procedure) of the Brazil–India Convention — As amended by the 2022 Protocol: a person who considers that the actions of one or both States result or will result in taxation not in accordance with the Convention may present the case to the competent authority of the State of which he is a resident within three years from the first notification of that action (previously five years).
Art. 15(2) of the Brazil–India Convention (as amended by the 2022 Protocol) — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the first State if (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period, (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and (c) it is not borne by a permanent establishment which the employer has in the other State. The original text (still applied by India to the previous year 2025-26) counted the 183 days «in the fiscal year concerned».
Art. 14 of the Brazil–India Convention (as amended by the 2022 Protocol) — Income of a resident of one State from professional services or other independent activities may be taxed in the other State if he has a fixed base regularly available to him there, or if he stays there for a period or periods amounting to 183 days or more in any twelve-month period commencing or ending in the fiscal year concerned. The original text taxed such income in the other State if it was paid by a resident of that State or borne by a permanent establishment there.
Income-tax Rules, 2026, rule 76; Forms No. 44 and 45 — A resident gets credit for foreign tax in the tax year in which the income is taxed in India; credit is the lower of the Indian tax on that income and the foreign tax, per source and per country; not against interest, fees or penalties; disputed foreign tax only after settlement (Form No. 45, within 6 months of the month of settlement). Form No. 44 with a certificate of income and tax and proof of payment, within 12 months from the end of the tax year if the return was filed on time; accountant verification if foreign tax is ₹1,00,000 or more. Conversion at the TT buying rate.
art. 115 RIR/2018; art. 4 Lei nº 14.754/2023 — Foreign income tax is deducted from Brazilian tax only if an international agreement with the source State so provides or that State grants reciprocity for income from Brazil; no more than the increase in Brazilian tax caused by including that income; for income under Lei 14.754/2023 an unused credit cannot be carried to other years.
Arts. 10–12-A of the Brazil–India Convention (as amended by the 2022 Protocol) — Limits on tax in the source State: dividends 10% (company holding at least 20% of the capital for 365 days) or 15% (Art. 10(2)); interest 10% (bank loans of at least five years) or 15%, with interest of the Governments, their subdivisions and central banks exempt (Art. 11(2)–(3)); royalties 15% for trademarks and 10% for others (Art. 12(2)); fees for technical services 10% (new Art. 12-A). Effective in Brazil for amounts paid from 1 Jan 2026, in India for income of previous years beginning on or after 1 Apr 2026. New Art. 26-A (limitation on benefits and principal purpose test) can deny the benefits.
Income-tax Rules, 2026, rule 75(3); Form No. 42 (application) and Form No. 43 (certificate) — Application for a certificate of residence for the purposes of an agreement under s. 159(1)–(2), filed on the e-filing portal (replaces Form 10FA): period for which the certificate is needed, basis of the residential status claimed, address in that period, supporting documents; the certificate is issued in Form No. 43.
Arts. 18–19 of the Brazil–India Convention — Pensions and similar remuneration for past employment are taxable in the State of residence, but may also be taxed in the other State if paid by a resident of it or by a permanent establishment situated there (Art. 18(1)–(2)); payments under a public social security scheme of a State are taxable only in that State (Art. 18(3)). Government salaries and pensions are taxable in the paying State; a government pension is taxable only in the other State if the recipient is a resident and national of it (Art. 19(2) as replaced by the 2022 Protocol).
Lei nº 15.191/2025 (monthly scale); arts. 3-A, 11-A Lei nº 9.250/1995 (as amended by Lei nº 15.270/2025) — Monthly scale from 2026: up to R$ 2,428.80 — no tax; then 7.5%, 15%, 22.5%; above R$ 4,664.68 — 27.5%. From 2026 the tax is reduced so that it is zero for taxable income up to R$ 5,000 a month; the reduction phases out up to R$ 7,350 a month (annual figures — R$ 60,000 and R$ 88,200).
arts. 6-A, 16-A, 16-B Lei nº 9.250/1995 (as amended by Lei nº 15.270/2025) — From 2026 — a minimum tax for people with total income above R$ 600,000 a year: the rate rises linearly to 10% at income of R$ 1,200,000 or more; the base includes exempt income and dividends (excluding capital gains, savings-account interest and certain tax-favoured securities); income tax paid and corporate tax (through a «reducer») are deducted from it. Dividends above R$ 50,000 a month from one company to one resident — 10% withholding.
EPFO — International Workers: Social Security Agreements — India's social security agreements operate with Belgium, Germany, Switzerland, Luxembourg, France, Denmark, Korea, the Netherlands, Hungary, Finland, Sweden, the Czech Republic, Norway, Austria, Canada, Australia, Japan, Portugal, Brazil and Quebec. EPFO issues a certificate of coverage to employees posted to those countries, so they avoid contributing in the host country; periods count toward pension eligibility.
Art. 4(2)(a) of the Brazil–India Convention — A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available in both States, of the State with which his personal and economic relations are closer (centre of vital interests). Art. 4 as replaced by the 2022 Protocol, which has effect in India for income of previous years beginning on or after 1 April 2026.
Art. 4(2) of the Brazil–India Convention, original text (1988) — Same sequence (permanent home, centre of vital interests, habitual abode, nationality, mutual agreement) — India applies it to the previous year 1 April 2025 – 31 March 2026.
Art. 4(2)(b) of the Brazil–India Convention — If the State in which he has his centre of vital interests cannot be determined, or if he has no permanent home available to him in either State, he is deemed to be a resident of the State in which he has an habitual abode.
Art. 4(2)(c), (d) of the Brazil–India Convention — If he has an habitual abode in both States or in neither of them, he is deemed to be a resident of the State of which he is a national (c); if he is a national of both States or of neither of them, the competent authorities settle the question by mutual agreement (d).

Updated 10/11/2026. The result is for information only and is not tax or legal advice. Tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes. Consult a qualified adviser before making decisions.

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