Tax residence in Brazil for Pakistani 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: residence begins on a specific date and ends on the day of definitive departure, and anyone who leaves without the notice of definitive departure stays resident for the first 12 months abroad. Pakistan counts its own tax year of 1 July – 30 June. There is no income tax treaty between Pakistan and Brazil, so dual residence is not resolved; Pakistan credits Brazilian tax under s. 103, while Brazil credits foreign tax only where reciprocity is proved.

Check your status: Pakistan and Brazil

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, 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 Pakistani tax rules

Collision: resident of both countries — no tie-breaker. Brazil treats you as resident — through permanent residence, a work visa, 184 days within 12 months or the first 12 months after leaving without the notice — and so does Pakistan: with 183 days in its tax year (1 July – 30 June), as a government employee posted abroad, or as a citizen under s. 82(d). Without a treaty nothing resolves the conflict: both countries tax your worldwide income. Pakistan credits Brazilian tax on Brazilian-source income up to the Pakistani tax on it (s. 103) and exempts Brazilian salary on which Brazilian tax was withheld and paid (s. 102); Brazil deducts Pakistani tax only if you prove reciprocity (art. 115 RIR/2018). Plan your days: a Pakistani citizen with fewer than 183 days in Pakistan who spends more than 182 days in Brazil in the Pakistani tax year and is a Brazilian resident taxpayer is no longer resident in Pakistan under s. 82(d).

What else to know

No income tax treaty between Pakistan and Brazil. Pakistan and Brazil have no treaty for the avoidance of double taxation: Brazil is not on FBR's list of Pakistan's full-scope treaties, and Pakistan is not on the Receita Federal list of Brazil's agreements. Consequences: no tie-breaker, so you can be a full resident of both countries at once; no 183-day rule protects short work trips; Brazilian withholding rates are not reduced; there is no mutual agreement procedure. Double tax is relieved only by each country's own rules: in Pakistan by the credit for foreign tax (s. 103) and the exemption of foreign salary taxed at source (s. 102); in Brazil a credit for foreign tax requires a treaty or proof that the other country grants reciprocity (art. 115 RIR/2018) — Receita accepts it without proof only for Germany, the United Kingdom and the United States.
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 a fixed year; if 184 days are not reached, a new 12-month period starts with the next entry. You become resident from the 184th day — and with a temporary visa to work under an employment contract, from the day of arrival. Pakistan counts 183 days within its tax year of 1 July – 30 June. The same trip therefore gives different counts: a stay in Brazil from 1 March to 31 October (245 days) makes you resident in Brazil from the 184th day, but falls into two Pakistani tax years — 122 days up to 30 June and 123 days after — so for s. 82(d) you were not in Brazil for more than 182 days in either of them. Keep a day count for both periods.
Year of moving: Brazil splits the year, Pakistan 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. Pakistan decides your status for its whole tax year (1 July – 30 June). A Pakistani citizen who leaves Pakistan during a tax year and stays abroad for the rest of it is exempt in Pakistan on salary earned abroad in that year (s. 51(2)); a citizen who returns after four non-resident tax years is exempt on foreign-source income in the year of return and the next (s. 51(1)). Without a treaty there is no mutual agreement procedure to reconcile the periods.
Leaving Brazil: the notice by the end of February. If you leave Brazil for good — for example to return to Pakistan — 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 — with no treaty to resolve an overlap with Pakistani residence. 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 Pakistan. Pay for work performed in Brazil is Brazilian-source income; for non-residents of Brazil 25% is withheld. Without a treaty there is no 183-day exemption for short work trips. A temporary visa to work under a Brazilian employment contract makes you resident in Brazil from the day of arrival. In Pakistan, salary earned in Brazil is exempt if the Brazilian tax on it was withheld by the employer and paid to the Brazilian tax authority (s. 102); otherwise Pakistan gives a credit for the Brazilian tax, limited to the Pakistani tax on that income (s. 103).
How double tax is relieved without a treaty. If you are resident in Pakistan, Brazilian tax on Brazilian-source income is credited against Pakistani tax on that income, computed separately for each head of income; unused credit is lost and the Brazilian tax must be paid within two years after the end of the Pakistani tax year (s. 103). If you are resident in Brazil, Pakistani tax is deducted only if you prove that Pakistan grants reciprocity for income from Brazil, and only up to the Brazilian tax on that income; for income under Lei nº 14.754/2023 an unused credit cannot be carried to other years (art. 115 RIR/2018). To prove the tax paid in Pakistan, ask the Competent Authority for a certificate of tax paid (rule 19B).
Pakistani 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 Pakistan are paid monthly (carnê-leão) at the progressive scale and included in the annual return. Interest, dividends and gains from financial investments in Pakistan 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. Pakistan still taxes your Pakistan-source income as a non-resident, usually by withholding (s. 101), and Brazil deducts that tax only if reciprocity is proved (art. 115 RIR/2018).
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.
Pensions without a treaty. Without a treaty no rule assigns pensions to one country. Brazil taxes its residents on worldwide income, including pensions from Pakistan (monthly carnê-leão), and taxes Brazilian pensions paid to non-residents by withholding — at the progressive scale rather than at 25% since the Supreme Federal Court's ruling (Tema 1.174). A pension paid by a Pakistani resident is Pakistan-source income (s. 101), so Pakistan can tax it even if you live in Brazil. If you are resident in Pakistan and Pakistan taxes a Brazilian pension, it credits the Brazilian tax (s. 103).
Pakistani government posting to Brazil. Federal and Provincial Government employees and officials posted abroad remain resident in Pakistan under s. 82(c), and their government salary is Pakistan-source income (s. 101). There is no treaty article reserving it to Pakistan; whether Brazil taxes it depends on Brazilian law and diplomatic privileges, which this package does not model.

How dual residence is resolved

There is no tax treaty in force between Pakistan and this country.

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

Is there a tax treaty between Pakistan and Brazil?

No. Brazil is not on FBR's list of Pakistan's full-scope treaties, and Pakistan is not on Brazil's list of agreements. There is no tie-breaker, no 183-day exemption for short work trips, no reduced withholding rates and no mutual agreement procedure. Pakistan credits Brazilian tax (s. 103) and exempts Brazilian salary taxed at source (s. 102); Brazil deducts foreign tax only under a treaty or proven reciprocity (art. 115 RIR/2018).

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 a fixed 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. Pakistan separately counts 183 days in its tax year of 1 July – 30 June.

What should I do when I leave Brazil for Pakistan?

File the notice of definitive departure (Comunicação de Saída Definitiva do País) by the last day of February of the following year and then 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 — with no treaty to resolve an overlap with Pakistani residence.

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%).
FBR — Bilateral full scope treaties (list of Pakistan's comprehensive income tax treaties) — Lists 68 treaty partners of Pakistan (page opened 10 Nov 2026); Brazil is not on the list.
Receita Federal — Acordos para evitar a dupla tributação e prevenir a evasão fiscal (list of agreements; page updated 28 Aug 2026) — Receita Federal's list of Brazil's agreements to avoid double taxation shows the agreements in force (and Germany as terminated); Pakistan is not on it.
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
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.
Perguntas e Respostas IRPF 2026, questions 136 and 142 (reciprocity for the foreign tax credit) — Receita treats Germany, the United Kingdom and the United States as granting reciprocity for income from Brazil, so Brazilian residents may deduct the income tax paid there without further proof (AD SRF 28/2000, AD SRF 48/2000, ADE SRF 72/2005, ADI SRF 16/2005); for other countries the taxpayer must prove reciprocity. Reciprocity does not extend to taxes paid to states and municipalities (question 142).
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; FBR consolidated text amended up to 30.06.2026) — Resident individual: one who, being a citizen of Pakistan, is not present in any other country for more than one hundred and eighty-two days during the tax year or who is not a resident taxpayer of any other country.
Income Tax Ordinance, 2001, s. 82(a) — An individual is a resident individual for a tax year if present in Pakistan for a period of, or periods amounting in aggregate to, 183 days or more in the tax year (1 July – 30 June).
Income Tax Ordinance, 2001, s. 51 — (1) A citizen who becomes resident in a tax year after being non-resident in the four preceding tax years: foreign-source income is exempt in that tax year and the following one. (2) A citizen who leaves Pakistan during a tax year and remains abroad for the rest of it: salary earned outside Pakistan in that year is exempt.
Income Tax Rules, 2002, rule 19B — A non-resident may apply to the Competent Authority of Pakistan for a certificate of tax paid in Pakistan (by deduction, collection or otherwise) for presentation to the tax authority of the country of residence; proof of residence in that country is required.
Income Tax Ordinance, 2001, s. 101 — Salary is Pakistan-source to the extent it is received from employment exercised in Pakistan (wherever paid) or is paid by or on behalf of the Federal, a Provincial or a Local Government in Pakistan (wherever the employment is exercised). Dividends of resident companies, profit on debt and royalties paid by residents, rent and gains on immovable property in Pakistan, gains on shares of resident companies and pensions paid by residents are Pakistan-source; everything else is foreign-source.
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.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.

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

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