001
Subsidiary incorporation
Corporate structuring for foreign capital entry, BACEN registration (RDE-IED), bank account opening, tax registrations (CNPJ, state and municipal), regularization with sector agencies.
International deskMultinationals & foreign companies
Foreign Companies
in Brazil.
Brazilian operations need to be legally translated for headquarters — without losing the local tax, labor, regulatory and contract reality.
— What we do
Six technical fronts.
The role of a Brazilian lawyer for a multinational is to translate risk — not just language. The fronts below are the ones that most demand that translation.
002
Cross-border contracts
Adaptation of contracts from headquarters to Brazilian reality, bilingual redline, negotiation with local counterparts and foreign legal liaison with parent legal.
003
Transfer pricing
Legal support for transfer pricing structuring after Law 14,596/2023 (OECD alignment), intercompany contract review, tax audit support and group reporting.
004
Regulatory compliance
Sector mapping (ANATEL, ANS, ANVISA, ANP, ANM, ANEEL), licensing, registrations, certifications and dialogue with regulators — interfacing with parent compliance.
005
HQ liaison
Structured reporting to parent legal — in format and depth compatible with international board and general counsel. Includes risk matrix, status of critical matters and short read of regulatory changes.
006
Corporate immigration
Visas for foreign managers (RNM), permanent residency tied to corporate investment (CNIg Normative Resolution 13), and expatriate regularization with the Federal Police and the Ministry of Justice.
— Legal references
The applicable framework.
Main statutes that guide the firm's practice in this area — no result promises, full reference.
Law 4,131/62
Foreign capital — Historic regulatory framework for foreign capital in Brazil: registration, profit remittance, interest on equity and reinvestment treatment.
Law 14,286/2021
New FX framework — Modernization of the Brazilian exchange regime — simpler transactions, foreign-currency accounts in Brazil and an updated BACEN regime.
Law 14,596/2023
Transfer pricing — OECD — Alignment of Brazilian transfer pricing with OECD guidelines, adopting the arm's length principle and new comparability rules. In force since 2024.
Decree 8,327/2014
CISG — United Nations Convention on Contracts for the International Sale of Goods — incorporated into Brazilian law.
Law 13,844/19 + CNIg
Corporate immigration — Regulatory framework for work visas and residency for expatriates in Brazilian corporate operations.
— Typical scenarios
Recurring situations.
Hypothetical scenarios that illustrate recurring situations: no clients, no case facts, no outcomes. Only the shape of the work, in line with Brazilian Bar (OAB) Provision 205/2021.
TYPICAL SCENARIO
Incorporation of a foreign group’s industrial subsidiary in Brazil
Typical situationA foreign industrial group decides to set up a manufacturing subsidiary in Brazil and must organize, in parallel, incorporation, registrations, a state incentive, intercompany contracts and the initial hiring of technical staff.
Legal issueDefine the corporate structure suited to the parent, the foreign capital registration, the regime of intercompany supply contracts under transfer pricing and the labor design of the initial operation.
How we workCorporate modeling with the parent, RDE-IED registration, bank account opening, intercompany contracts under transfer pricing, start-up labor plan and ongoing interface with parent legal and tax teams, in English.
TYPICAL SCENARIO
Adaptation of intercompany contracts to Law 14,596/2023
Typical situationA Brazilian subsidiary of a foreign group holds several intercompany contracts (royalties, technical services, financing, among others) and must review them under the new transfer pricing regime of Law 14,596/2023.
Legal issueCheck whether each contract reflects the arm’s length principle, adjust remuneration and risk allocation and align documentation with the requirements of parent tax and the external auditor.
How we workLegal-tax diagnostic of each contract, drafting of addenda in English with a Portuguese version, alignment with the parent transfer pricing team and organization of the elements for the comparability benchmark.
— Frequently asked
Five direct questions.
The questions we get most often before the first meeting — answered without legalese.
How long does it take to incorporate a subsidiary in Brazil?
60 to 120 business days for a full setup — from filing parent documents (with sworn translation and apostille) to effective operation (CNPJ, bank account, tax registrations).
Regulated sectors (health, financial, energy, telecom) can add another 60–180 days for sectoral registrations.
Does the new transfer pricing law require rewriting all intercompany contracts?
Not necessarily. But each contract must be re-read under the new arm's length logic of Law 14,596/2023 — some will be kept, others amended, and few effectively restructured.
The diagnostic identifies the right path for each contract. Wholesale rewriting is usually unnecessary and not always the safest route.
How does the interface with parent legal work?
We work directly in English with general counsel, regional counsel and international tax departments. Monthly or quarterly reports in board-compatible format (risk matrix, status of critical matters, short read of regulatory changes).
For parent committees we participate via videoconference. For in-person hearings outside Brazil, we articulate via trusted international correspondents.
Is Brazil still hostile to foreign capital?
Less than it seems — and more than is advertised. The exchange regime was modernized in 2021 (Law 14,286), transfer pricing aligned with OECD in 2023, and BACEN has been simplifying FDI registrations.
On the other hand, tax enforcement remains intense, and regulated sectors still require careful reading. The right question is not whether Brazil is hostile, but which structure minimizes friction.
Do you handle ZPE or incentive-zone operations?
Yes. We have experience with state incentive regimes across different Brazilian states (including state tax authorities, regional development banks and border ICMS) and with federal regimes such as Rota 2030, Mover and Sudene. For ZPE, we work with a regional correspondent in the target area.
International desk
Start with 15 minutes.
Conversation in English, Portuguese or Spanish. In 15 minutes we read the Brazilian operation (established or planned) and indicate where the firm can add value to the work of in-house counsel and headquarters.