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.
— Cases
Two anonymized examples.
In compliance with OAB Rule 205/2021: no party names, no case numbers, no result guarantees, no comparisons. Only the shape of the work.
CASE I-01 2024
Incorporation of a German industrial subsidiary in Brazil
ClientGerman industrial group establishing a manufacturing subsidiary in Brazil to serve the South American market.
ChallengeStructure the Brazilian subsidiary in parallel with negotiation of a state incentive (with the competent state tax authority), incorporation, registrations, intercompany supply contracts and initial technical hiring.
WorkCorporate modeling with parent, RDE-IED registration, bank account opening, intercompany contracts under transfer pricing, start-up labor plan, ongoing interface with parent legal and tax in German and English.
OutcomeSubsidiary operational within the 11-month schedule. First exported production per plan. State incentive approved and in force.
CASE I-02 2023 — 2024
Adaptation of intercompany contracts to Law 14,596/2023
ClientBrazilian subsidiary of a North American consumer goods group, with five active intercompany contracts (royalties, technical services, distribution, financing, cost-sharing).
ChallengeAdapt the five intercompany contracts to the new arm's length logic post Law 14,596/2023, in interface with parent tax and a Big-4 international auditor.
WorkLegal-tax diagnostic of all five contracts, drafting of addenda in English with certified Portuguese version, alignment with parent transfer pricing team, submission to comparability benchmark.
OutcomeFive addenda signed before the fiscal year end. Revised position reflected in the transfer pricing declaration with no auditor qualification.
— 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.