Create a company in Cyprus — or move your company from Brazil

On 1 January 2026 Brazil started taxing dividends again, ending an exemption that had stood since the 1996 results year. A resident individual is now withheld 10% where one company pays them more than R$50,000 in a month, and a beneficiary abroad is withheld 10% on every real. Almost every page you will read still says otherwise.

Updated for 2026 Cyprus tax law and regulations.

One partner for the Brazilian exit and for the Cyprus company you open next

Sumly is the one-stop, fully digitalized way for a founder in Brazil to create a company in Cyprus, relocate the business here and then actually operate it — from São Paulo, from Limassol or from somewhere over the Atlantic. We register the company, open your books the day you order, prepare every Cyprus return box by box, and run the tax residency and non-dom application as one fixed-price service. One dashboard, one provider, four published prices.

This is Sumly — and what we actually do for you

Sumly is the fully digital provider for founders moving a company to Cyprus. You do not need to learn Cypriot company law, find a local auditor, or work out which form goes where. You get in touch, and we do the rest.

And we stay with you on both sides of the move. The Cyprus side we own outright. For the side you are leaving, we put you straight in front of an adviser or lawyer from our network who works on exactly your problem — company law, exit taxation, inheritance, employment — and we hold the thread between them and us. One point of contact for the whole move, however many specialisms your case turns out to touch. If your case is simple, we do all of it for a fixed price.

Part 1: What leaving actually costs you

Your home country does not let go the moment the plane does. What still runs after you have left, and in which order it has to be handled.

Where does Brazil genuinely beat Cyprus, and who should simply stay?

Before any argument for moving, the honest side of the ledger, because a large share of the founders reading this should not go anywhere.

Brazil charges you nothing to leave. There is no deemed disposal of your shares, no deferred charge, no security to post — which is a very large advantage over Germany, Spain, Canada, Australia or Norway, and it means the decision stays reversible in a way it does not from those countries. The top personal rate is 27.5%, which is not a high-tax ladder by European standards, and from 2026 monthly income up to R$5,000 pays no income tax at all. Money moves out of the country without permission and without a ceiling. Simples Nacional is genuinely generous up to R$4,800,000 of annual revenue, and it is precisely what emigration takes away.

Then the concession that matters most, and that no competitor page will make: the new dividend charge does not reach most people. It bites only where a single company pays a single resident individual more than R$50,000 in one month, and the new minimum personal tax starts only above R$600,000 of total annual income. A founder drawing R$40,000 a month from one company and staying under that annual figure pays nothing new in 2026. If that is you, the reform is a headline rather than a bill, and moving your life across an ocean to solve it would be an expensive way to fix a problem you do not have.

The rest of this page is for the founders above those lines — and for the ones whose profit is in software, licensing or anything else where a 34% corporate stack and a 3% Cyprus IP Box are separated by an ocean and a filing.

What exactly did Lei 15.270/2025 change for a Brazilian founder?

Three charges, all live from 1 January 2026, and one deletion that most readers will miss entirely.

The old caput of art. 10 of Lei 9.249/1995 exempted profits and dividends paid to a beneficiary domiciliado no País ou no exterior. The new caput says domiciliado no País — full stop. The words "ou no exterior" were deleted, and in their place sits a new paragraph charging 10% withholding on profits or dividends paid, credited, delivered, employed or remitted abroad. Anyone comparing the old text to the new one and missing that deletion will reach the opposite of the truth.

Read the domestic limb carefully: the 10% applies to the total amount paid, not to the excess above R$50,000, and no deduction from that base is allowed. Read the outbound limb carefully too, because it is the one that decides this guide. A founder who moves to Cyprus and keeps the Brazilian operating company does not escape into an exemption — they walk into a withholding that starts at the first real, with no treaty to reduce it.

There is one relief and one closed door. The relief is an optional credit for the non-resident where the paying company's own effective rate plus ten percentage points exceeds the nominal sum of corporate charges, claimable within 360 days counted from each financial year in a manner to be regulated. The mechanics of claiming it were not yet published in operational detail when this page was written, so treat it as a line to raise with your contador rather than a number to plan on.

The closed door is the grandfathering. Profits earned up to calendar 2025 whose distribution was approved by 31 December 2025 by the competent corporate body, and paid on those originally approved terms, stay outside both the withholding and the minimum tax — with a payment window running through 2026, 2027 and 2028. Check your minute book first: this is binary, it is dated, and it cannot be arranged retrospectively.

Why is quoting "15% corporate tax in Brazil" wrong by more than half?

Because Brazilian corporate profit carries three federal charges, not one, and any page quoting only the first is out by a factor of more than two.

The base rate is 15%, the surcharge is 10% on the part of profit exceeding R$20,000 per month of the assessment period, and the social contribution on net profit is 9% for an ordinary company. It is unusual to be able to cite the legislature for an arithmetic sum, but here you can: when Lei 15.270/2025 defined the ceiling for its new reducer it stated the nominal sum of corporate income tax and CSLL as 34%, with 40% for insurers and most financial entities and 45% for banks under the 2025 amendments to the CSLL rates. So 34% is not an analyst's addition. It is on the face of a statute.

The surcharge threshold is R$240,000 of annual profit. For any company large enough to be weighing an international move, the surcharge applies to essentially all of the profit, which is why 34% is the honest headline and 15% is not. Cyprus, for the same profit, charges 15% from tax year 2026.

What does a Cyprus company do to your Brazilian company's own filing regime?

This is the second-order cost almost nobody prices, and it arrives whether or not anything is distributed.

Most founders in this audience sit on Lucro Presumido, where the company applies a statutory presumption to gross revenue instead of measuring real profit — 32% for services in general, against 8% of gross revenue for commerce and industry. It is simple, it is cheap to administer, and it is the regime a software or consulting company usually lives in.

Then read the ceiling provision. Lucro Real becomes compulsory where revenue in the prior calendar year exceeded R$78,000,000 — and, separately, for any company that has profits, income or capital gains originating abroad. That second limb has no size threshold whatsoever. A ten-person Brazilian services company that acquires a Cyprus subsidiary, or that simply earns some foreign-source income, is thrown out of Lucro Presumido and into full accounting profit, transfer pricing documentation and the corporate rules on controlled foreign entities.

Put in the terms a founder actually cares about: forming in Cyprus does not only add a Cyprus filing. It changes the Brazilian company's own regime, permanently, and adds a recurring accountancy bill in Brazil that was never in anyone's spreadsheet. If your Brazilian company is going to keep trading, decide deliberately whether it should own anything abroad — because in most structures it should not.

Is Cyprus on Brazil's favoured-taxation list, and does that decide the guide?

Yes, and very nearly. This is the fact a Brazilian reader must check before believing anything else on any Cyprus page, including this one.

Cyprus appears by name as "XVI - Chipre" in the Receita Federal's list of countries and dependencies with favoured taxation. It has been there since 2010 and it is still there: the list was last amended in May 2025, and that amendment removed the United Arab Emirates and the Austrian holding regime while leaving Chipre untouched. Singapore, Costa Rica, Madeira, Switzerland and San Marino have all come off over the years. Cyprus has not. Ireland, incidentally, is on the same list.

The same amendment lowered the rate line. The statutory definition now reaches a country that does not tax income or taxes it at a maximum rate below 17%. Cyprus's corporate rate from 2026 is 15%. Its IP Box regime brings qualifying profit to 3% from tax year 2026. Both sit below the line, so Cyprus would qualify on the rate test even if it were not named — and the rise from 12.5% to 15% changed nothing here.

One more trap in the same instrument. IN RFB 1.037/2010 has two operative articles: art. 1º lists jurisdictions, art. 2º lists named privileged regimes inside otherwise ordinary countries — Maltese international holding companies, Spanish ETVEs, Dutch and Danish holding companies without substantive activity, Madeira's international business centre. Cyprus is not in art. 2º, and it does not need to be, because the whole country is in art. 1º. A reader who looks for Cyprus among the named regimes, fails to find it, and concludes Cyprus is clean will invert every conclusion below.

Do Brazil's offshore rules catch a Cyprus company you own?

If you are still a Brazilian tax resident, yes — automatically, unconditionally, and without any substance defence.

Since 1 January 2024 the profits of foreign entities controlled by Brazilian-resident individuals are taxed at 15%, on 31 December of each year, and the statute says in terms that the profits enter the annual return independently of any decision about their distribution. Control is the ordinary test: preponderance in corporate resolutions, or more than 50% of the capital or of the profit rights, alone or with related persons.

The trigger is the part people get wrong. Only controlled entities meeting one of two limbs fall inside the annual charge: location in a country with favoured taxation or benefit from a privileged fiscal regime, or own active income below 60% of total income. It is an either/or, and the first limb is a pure location test. A hundred employees in Limassol, a real product, real customers and a genuinely active trading business change nothing, because you never reach the second limb once the first is satisfied — and Cyprus satisfies it by name. The structuring instinct that works under European anti-avoidance rules, giving the company real substance, does not work here.

There is a compliance sting attached that is easy to miss. Accounts for the controlled entity may be prepared to IFRS or to Brazilian standards at the taxpayer's option — except that an entity in a favoured-taxation country must use Brazilian accounting standards. Your Cyprus company's statutory accounts will not do. Someone has to produce a second set of numbers, every year, for as long as you remain resident.

For a Brazilian company owning the Cyprus entity it is worse still, because the corporate regime has no trigger test at all: all controlled foreign profit is computed in the parent's lucro real and CSLL base annually, consolidation is unavailable for an investee in a favoured-taxation country, and deferral for non-controlled affiliates is denied on the same ground. Full inclusion at 34%, no consolidation, no deferral, credit only for the 15% Cypriot tax, and forced Lucro Real underneath it.

The conclusion is unusually clean for a tax question. If Cyprus is going to be used, it should be owned by an individual who has genuinely and provably left Brazil — not by a Brazilian company, and not by an individual who has stayed.

Does Brazil charge an exit tax, and how do we know?

No, and it is worth showing the working rather than asserting a negative, because this is a real advantage and readers are right to be sceptical of free lunches.

The whole of the departure procedure sits in five articles of IN SRF 208/2002. They require a communication, a return covering the months of residence, payment in a single instalment, and a late-filing penalty. None of them deems any asset to be disposed of. The tax in the departure return is computed on the monthly progressive table of the year of departure, multiplied by the number of months of residence in that year — an ordinary income computation truncated mid-year, not a wealth event. The chapter of the Income Tax Regulation headed Da transferência de domicílio imposes duties to notify and to appoint a representative, and contains no charging provision. Capital gains attach to an alienação, and emigrating is not one. Lei 14.754/2023 taxes people who are resident; its only mark-to-market bites on a transfer of assets between entities, not on leaving.

So the answer is a genuine no, and against Germany, Spain, Canada, Australia or Norway it is a large advantage. What Brazil does instead is two things that are easy to mistake for an exit tax and are not one: a condition on recognising the move, and a twelve-month worldwide tail for people who do not file the forms. Both are below.

Why does Cyprus's 60-day rule not end your Brazilian tax domicile?

Because Brazil applies a special rule to a founder whose destination is on the favoured-taxation list, and it asks for more than three times as many days.

Art. 29 of the Regulamento do Imposto sobre a Renda, enacting Lei 12.249/2010, provides that a transfer of tax domicile from Brazil to a country with favoured taxation or a privileged fiscal regime has its effects recognised only from the date on which the taxpayer proves either de facto residence there, or subjection to and actual payment of tax on the totality of income from work and capital. And it defines the first limb for you: de facto resident means having effectively remained in the country for more than one hundred and eighty-three days, consecutive or not, in a period of up to twelve months, or proving that the habitual residence of the family and the greater part of the patrimony are located there.

Now set that against what the Cyprus pages sell. The Cyprus rule got easier in 2026 — the condition of not being tax resident anywhere else was removed from the 60-day rule, leaving four conditions: at least 60 days in Cyprus, no more than 183 days in any other single state, a business, employment or office in a Cyprus tax-resident person held through the year, and a permanent home in Cyprus owned or rented. All of that is true, and none of it answers Brazil's question. Sixty days makes you Cypriot for Cypriot purposes. It does not make Brazil stop counting you.

Worse, the second limb of art. 29 is effectively closed to the very reader most attracted to Cyprus. It asks for tax on the totality of work and capital income, and for proof of effective payment. A non-domiciled Cyprus resident is outside the Special Defence Contribution on dividends for 17 years — which is the entire attraction, and which is exactly why the capital half of that test cannot be satisfied. The feature you came for is the feature that fails the test.

Practically, that leaves one route and a fallback. Count more than 183 days in Cyprus across a rolling twelve months, and keep the evidence as you go: entry and exit records, boarding passes, a Cypriot lease or deed, utility accounts, school enrolment, the Cypriot tax residency certificate. If you cannot do the days, you need both halves of the alternative — family home in Cyprus and the greater part of your patrimony there. Family in Limassol while the bulk of the assets sit in Brazilian companies and Brazilian property does not satisfy it. The article puts the burden of proof squarely on you.

How do you actually end Brazilian tax residency, step by step?

Two documents, two deadlines, and they are not the same document. Conflating them is the commonest error in Portuguese-language content on this subject.

The Comunicação de Saída Definitiva do País comes first. It is filed from the date of departure until the last day of February of the following calendar year, and the same article says expressly that it does not dispense with the declaration. Dependants holding a CPF who leave on the same date go on it.

The Declaração de Saída Definitiva do País comes second, covering the part of the calendar year in which you were resident, due by the last business day of April of the following calendar year, together with any earlier returns still outstanding. That April date has been administratively extended in every recent year; for the 2026 season it was moved to 29 May 2026. Never publish or rely on a hard date without re-reading the current year's instruction, because it moves annually.

Then two obligations people forget. The tax assessed in the declaration, and every other unpaid credit, must be paid in a single instalment by that deadline — there is no instalment option. And you must tell every Brazilian paying source, in writing, the date of your definitive departure, so that withholding is applied on the right basis.

What happens to your Simples Nacional company when you emigrate?

It stops being a Simples company, automatically, and there is no planning step that prevents it.

Simples Nacional is barred for any company whose holder or partner is domiciled abroad. And a CNPJ update notifying the inclusion of a foreign-domiciled partner is equivalent to the mandatory notice of exclusion from Simples Nacional in its own right. Your own compliance step triggers it.

The company then falls into Lucro Presumido or, if it has foreign income, straight into Lucro Real. For a services business on the 32% presumption, that is a material increase arriving in the same year as everything else. Model it six months before you leave, not in the month the exclusion notice arrives — and note that this is a tax rise caused by the move itself, quite apart from anything Cyprus does or does not charge.

What does a non-resident actually pay on Brazilian income — and why 25%?

Once you have left, the Brazilian company you leave behind pays you through exactly three doors, and one of them is more expensive than you expect.

The middle row is the one that surprises people. IN SRF 208/2002 applies 25% instead of the ordinary rate where the beneficiary is resident in a country with favoured taxation, and that residual category expressly includes interest on own capital. Services and technical assistance carry the same penalty rate under a parallel provision. So a founder who moves to Limassol and keeps invoicing their Brazilian company for management or development services is in the 25% bracket, not the 15% one, purely because of where they now live.

The third row has its own trap. A non-resident's Brazilian capital gain is taxed at 15%, collected by the seller or their attorney on the date of the sale, none of the resident exemptions and reductions apply, and where the acquisition cost cannot be documented it is treated as zero. If you cannot evidence what you paid for your quotas fifteen years ago, you will be taxed on the whole proceeds. Reconstruct that file while you are still resident and can still get documents easily.

For comparison, a resident selling the same asset faces a ladder of 15% up to R$5m, 17.5% to R$10m, 20% to R$30m and 22.5% above. Cyprus, by contrast, does not tax gains on securities at all.

Is there a Brazil–Cyprus tax treaty, and what does its absence change?

There is none, and it is worth stating flatly because it changes five things at once.

Cyprus does not appear on the Receita Federal's own list of agreements to avoid double taxation, which runs to thirty-nine countries including Portugal, Spain, the Netherlands, Luxembourg, Austria, Hungary and Finland. Brazil does not appear on the Cyprus Ministry of Finance's own list either. Two independently maintained government lists agree, which is about as close to proof of a negative as this kind of question gets.

What follows: no reduced withholding on anything, so the 10% on dividends and the 25% residual are full rates; no residence tie-breaker and no mutual agreement procedure if Brazil disputes your departure under art. 29, so the argument is decided by Brazilian domestic law alone; no capital-gains article, so the saving clause in the 15% rule has nothing to attach to; and no treaty route to a foreign tax credit — a credit requires a treaty providing for it or proven reciprocity of treatment, and with no treaty a Brazilian resident has to establish reciprocity through sworn-translated, authenticated copies of the Cypriot law or a declaration from the Cypriot authority. No published act recognising reciprocity with Cyprus was found for this guide, so treat that route as work rather than a formality.

Be honest with yourself about what this means. If you are choosing an EU destination purely on treaty coverage, do not choose Cyprus. Portugal, Spain and the Netherlands all have treaties with Brazil and Cyprus does not. The Cyprus case has to be made on the destination regime — the rate, the IP Box, the dividend layer, the EU market — because there is no treaty network to make it on.

Does Brazil tax wealth or inheritance once you have gone?

Wealth, no. Inheritance, quite possibly — and the reason is counter-intuitive enough that it is the answer to the commonest fantasy in this space.

Brazil levies no net wealth tax. The Constitution reserves competence for one on grandes fortunas, nos termos de lei complementar, but the complementary law that competence depends on has never been enacted, and no such charge appears anywhere in the income tax legislation. Cyprus levies no net-wealth tax and no inheritance tax either, so on this axis the two countries draw.

ITCMD is different, and it is a state tax, so there is no single Brazilian rate to quote — there are twenty-seven regimes. The constitutional ceiling is 8%, in force since 1 January 1992, and no state may exceed it. São Paulo currently charges 4%. Other states set their own, and the 2023 constitutional amendment made progressivity by the size of each share mandatory rather than merely permitted, so flat-rate states are moving to scales and the direction of travel for large estates is towards the ceiling.

Here is the part that matters to an emigrating founder. Pending the complementary law, the transitional rule provides that for the assets of a deceased person, even where situated abroad, the tax belongs to the state where they were domiciled — or, if they were domiciled or resident abroad, to the state where the heir or legatee is domiciled. Read that against your own family. Move to Cyprus, die domiciled there, leave the Cyprus company to children still living in São Paulo, and ITCMD is due to São Paulo. Emigrating does not take your estate out of Brazilian inheritance tax if your heirs stay. Cyprus's absence of inheritance tax is a real win — but only if the family moves too.

Can you move the money, and what must you keep reporting?

You can, freely, and this is one of the least appreciated advantages a Brazilian founder has over, say, an Argentine one. The 2021 exchange statute states that operations in the exchange market may be carried out freely, without limitation of value, at a rate freely agreed between the authorised institutions and their clients. The friction is a bank's onboarding and the purpose code on the contract, not a central-bank authorisation.

What you owe instead is a report — and Brazilians file two separate foreign-asset reports to two different bodies, which is where most people trip. The annual Declaração de Capitais Brasileiros no Exterior goes to the Banco Central, not the Receita, and is required where assets abroad total US$1,000,000 or more on 31 December, filed between 15 February and 5 April of the following year. For jointly held assets each holder counts the full value against the threshold but declares only their own share — so a couple holding US$1.2m jointly are both obliged to file even though neither owns a million. Supporting documents are kept for ten years, and the schedule now expressly reaches virtual assets and patrimony transferred to a foreign fiduciary for named Brazilian beneficiaries.

The obligation attaches to residents, so a clean departure eventually removes it. The sequencing trap is the 31 December position rather than the departure date: leave late in the year without completing the process, or trip the twelve-month tail, and you were resident on a base date you thought you had escaped.

What happens to INSS and your Brazilian pension?

There is no social security agreement between Brazil and Cyprus. Cyprus does not appear among the international agreements in force published by the Ministério da Previdência Social, which covers Germany, Austria, Belgium, Canada, Spain, France, Greece, Italy, Portugal, Switzerland and others, plus the Ibero-American and Mercosur instruments.

Three consequences follow, and all of them are structural rather than numerical. There is no totalisation, so Brazilian and Cypriot contribution periods cannot be aggregated to qualify for a benefit in either country — a founder with fifteen years of INSS and ten years of Cypriot social insurance can end up short of the qualifying period in both. There is no certificate of coverage to avoid contributing twice during a transition. And EU coordination, which does this job between Cyprus and other member states, does not reach a Brazilian who has never worked elsewhere in the EU. Take advice on the INSS side from a Brazilian specialist before you stop contributing; this guide deliberately publishes no INSS figures, because none could be verified against an official source at the level of precision a decision needs.

Part 2: What Cyprus gives you

This is the straightforward half, and the half we build end to end. What you actually get on the other side.

What does the Cyprus side look like for a Brazilian founder?

Simpler than the Brazilian side, which is the point. Corporate tax is 15% from tax year 2026, against a Brazilian stack of 34%. On the personal ladder, the first slice is untaxed and the top rate arrives late: 0% to €22,000 rising to 35% above €72,000. A non-domiciled resident is outside the Special Defence Contribution on dividends for 17 years, while a domiciled shareholder pays 5% on dividends from 2026 profits. The health contribution is 2.65% on income up to €180,000 a year, which is the only personal charge a non-dom meets on a dividend. VAT registration starts at €15,600 of turnover, at a standard rate of 19%. Cyprus levies no net-wealth tax and no inheritance tax.

For a product company the largest number on the page is the IP Box, which brings qualifying profit to 3% from tax year 2026. The IP Box is the largest single line in a Cyprus product company's tax position — and the easiest one to forfeit through bookkeeping that was never set up for it. The application starts as a conversation rather than a form, which is why it is scoped in a meeting; the IP Box service page sets out what qualifying income has to be able to prove.

How does a Brazilian founder become Cyprus tax resident?

Two routes exist, and for a Brazilian only one of them is safe to rely on. The 183-day route is the ordinary one. The 60-day route got easier in 2026, but as set out above it does not answer Brazil's art. 29 question — so a Brazilian founder should plan for the days, and treat the Cypriot 60-day rule as a floor rather than a target.

Non-dom status is the piece that makes the dividend layer work, and it runs alongside residency rather than following automatically from it. Sumly handles both as one fixed service at €750 per person: the residency application, the non-dom registration, the certificate, and the file behind them. If you don't qualify, we tell you before you pay. The Yellow Slip route is an EU-citizens-only registration under EU law, so it is not the Brazilian route and we promise nothing about it — the non-dom guide and the 60-day rule explained set out how the two pieces fit together.

Why do people choose Cyprus over other tax havens?

Because the low-tax jurisdictions a Brazilian founder is usually shown ask you to spend your years somewhere you would never have chosen to spend them. Cyprus has among the lowest violent crime rates in the EU. English is spoken everywhere, which for a Brazilian founder already operating internationally removes a whole category of friction that Portugal's language advantage does not fully offset once you count the tax difference. The island already holds people from everywhere, which means a Brazilian founder is never the novelty in the room. Business and real estate are both growing. Regulation is light and the authorities are open to people who want to build something. The beaches are genuinely usable — in a Cyprus winter you can still swim, and the summers are what people fly across continents for. Groceries are affordable, and meat, fruit and vegetables in particular cost a fraction of what a São Paulo family expects to pay for the same quality.

The Brazil-specific push factors are honest ones rather than slogans. A 34% corporate stack that a founder cannot plan around. A dividend regime that changed in one statute after thirty years of stability, which tells you something about how stable the next thirty will be. Compliance overhead that is heavy even by emerging-market standards, and a consumption-tax transition running underneath everything through the rest of the decade. And, for anyone building software or licensing IP, no domestic equivalent of an IP Box at any rate.

Can a Brazilian e-commerce brand run through Cyprus?

Yes, and for a direct-to-consumer brand selling into Europe it is often the clearest reason of all, because it solves a market problem rather than only a tax one. A Cyprus company is inside the single market: EU VAT, VIES, euro settlement and EU counterparties who no longer treat you as an unfamiliar cross-border risk.

The bookkeeping is where these businesses usually drown, and it is the part we automate. The Shopify and WooCommerce plugins pull every order, refund, fee and payout into the ledgers with the right Cyprus VAT treatment applied, so the store's books are on autopilot instead of being rebuilt from CSVs each quarter. The service pages for Shopify bookkeeping and WooCommerce bookkeeping set out what each connection covers.

Two worked examples

Both are stated in euro at the company level so the two systems compare like for like; your own real figures depend on the rate on the day you convert. Both assume the profit is fully distributed and that the founder is above the thresholds where the new Brazilian dividend charge actually applies — which, as said at the top, many readers are not.

A services company at €300,000 of profit. In Brazil the company pays the 34% stack, about €102,000, leaving €198,000 to distribute. The 10% dividend layer takes a further €19,800, and the founder keeps roughly €178,200 — an all-in rate of about 41%. Through Cyprus the company pays 15%, or €45,000, and a non-dom shareholder distributing the remaining €255,000 meets only the health contribution, capped at €4,770, keeping about €250,230. The gap in a single year is around €72,000, and the calculator at the top of this page compounds it, because each year's difference is invested and Cyprus does not tax the return on it.

A software company at €600,000 of profit with qualifying IP. In Brazil the stack is unchanged — there is no domestic incentive that reduces it — so €600,000 becomes €396,000 after corporate charges and about €356,400 after the dividend withholding. In Cyprus, qualifying profit under the IP Box is taxed at an effective 3%, leaving €582,000, and the distribution again meets only the capped health contribution: roughly €577,230. The gap is around €221,000 in year one. This is the profile where the difference stops being incremental and becomes structural — and it is also the profile where the art. 29 day count deserves the most attention, because a software company whose founder still spends most of the year in Brazil has moved a letterhead, not a business.

Part 3: How the move runs

From the decision to the first invoice out of the Cyprus company: the order, the mistakes people make before you, and two calculations worked through in full.

What does the move look like, month by month?

Timelines depend on your own facts, your bank and the Registrar's queue, so read this as shape rather than schedule.

• Before anything else — and this is our first question to you. We check the minute book with your Brazilian adviser. If retained profits earned to 2025 had their distribution formally approved by 31 December 2025, there is a window to pay them out on those terms through 2028 outside the new charges. If not, that window is closed and cannot be reopened — and you should know which it is before anything else moves.
• Six months out. Your Brazilian adviser models the Simples exclusion, if it applies to you, and reconstructs the acquisition cost of your quotas while the documents are still easy to obtain. We settle with you who will own the Cyprus company — and in almost every case the answer is a founder who has genuinely left, not the Brazilian company.
• Month 1. We incorporate in Cyprus, ordered online, with the books live from the same day. You start the Cyprus lease or purchase that the residency rules require — we tell you what qualifies — and you start counting days properly from the first one.
• Months 1–3. We handle the Cyprus VAT registration, plus social insurance, employees and UBO where they apply, and get banking and EU payments moving. You take up the directorship or employment that anchors the Cyprus side.
• Departure day and the day after. Non-residence begins on the date of a permanent departure — subject to the communication being filed. Your Brazilian adviser notifies every Brazilian paying source in writing.
• By the last day of February following. Your Brazilian adviser files the Comunicação de Saída Definitiva do País.
• By the April deadline as extended for that year. Your Brazilian adviser files the Declaração de Saída Definitiva do País and pays in one instalment.
• The first 31 December. Two questions, and your Brazilian adviser answers both. Were you Brazilian-resident on that date, including through the twelve-month tail? Were assets abroad US$1m or more while you were still resident? Each has a filing behind it.
• Throughout. We build the art. 29 evidence file contemporaneously with you. It is the difference between a move Brazil recognises and one it does not.

What mistakes do Brazilian founders actually make?

Almost all of them are the same mistake in different clothes: treating the Cyprus formation as the move, when the move is a Brazilian evidentiary exercise that happens to end in Cyprus.

Spending sixty days in Limassol on the strength of a Cyprus page and assuming Brazil accepts it. Filing the declaration and forgetting the communication, or the reverse, and discovering that the twelve-month worldwide tail applied all along. Incorporating in Cyprus while still Brazilian-resident and being surprised by a 15% charge on 31 December for profits nobody distributed. Putting the Cyprus company under the Brazilian company, and inheriting full annual inclusion, no consolidation, no deferral and forced Lucro Real in one decision. Continuing to invoice the Brazilian company for services from Cyprus at what they assume is 15%, and meeting 25%. Selling quotas without a documented cost base. Assuming that emigrating removes the estate from ITCMD when the children are still in São Paulo. And relying on a foreign tax credit for Cypriot tax without a treaty, without reciprocity established, and without noticing the difference.

Part 4: Who does the work

You can do all of this yourself. Below is what that costs in time and in money, against what it costs to let us do it.

Do it yourself — or have Sumly do it

Neither route is a trick question, and switching from the first to the second is common enough that we price for it. Doing it yourself means the Registrar's forms and fees, a registered office you arrange, VAT and VIES registration, provisional tax twice a year, annual statements and books that will survive an auditor — while you are also managing a two-country move and a Brazilian exit file across a five- or six-hour time difference. Sumly's route is published prices: formation from €950 one-time, the software from €39 a month, your own Sumly certified bookkeeper at €390 a month, and tax residency with non-dom at €750 per person, with books opened the day you order.

The software alone runs the whole company from Cyprus or from Brazil: invoicing, AI double-entry bookkeeping, live open-banking feeds, all VAT, VIES, provisional and corporate returns prepared box by box, live reports, a document inbox with its own email address, mobile receipt capture that books itself, multi-currency invoicing, team roles and the AI assistant — plus payroll at €15 per employee per month, IP Box tracking at €50 a month, Projects at €10 a month, and the e-commerce plugins.

Sumly, a law firm, and a traditional bookkeeping firm

Law firm vs Sumly — and what happens when a case gets complicated

Sumly is cheaper and faster, and we work WITH lawyers, not against them. When a case gets too complicated for what Sumly handles directly, we simply connect you with the right expert in exactly the legal field you need help in, and everything gets done according to best practice, always. Either way, it starts the same place: contact us.

Sumly offers all of this to everyone who asks: a virtual address with PO box, with your post scanned and delivered into the dashboard wherever you are that week; nominee director and secretary where a structure genuinely needs them; every registration handled — VAT, social insurance, employees and UBO; audit through Partner Auditors; banking and EU payments sorted, though no provider can promise you a particular bank's decision; and the Yellow Slip, which is an EU-citizens-only route and therefore not the Brazilian one.

Each of those is an extra, scoped to your case. Tell us what you need in the meeting and you get one clear package-deal offer covering all of it, the IP Box application included where it fits, since that is complex expert work that should be looked at with you before anyone puts a number on it. No hourly billing and no surprises. That combination — a fixed Cyprus price, one dashboard, and plain honesty about where the Brazilian side needs a Brazilian professional — is what makes Sumly the best choice for Brazilian founders creating a company and relocating to Cyprus.

Why is Sumly the best bookkeeping system for a Cyprus company?

Sumly is the best accounting software for a Cyprus limited company — because it is built for exactly one thing, Cyprus tax law: all 16 Cyprus VAT codes mapped to the official VAT return boxes, VIES and provisional tax native, not a localization. That is the claim, and every line under it is checkable.

The two Cyprus-built alternatives a Brazilian founder will be shown are Cybooks and Balabook. We meet their former customers every week, and what they tell us, again and again: workflows that made simple bookkeeping overly complicated, rough edges and glitches, support that left them waiting — a messy experience they were relieved to leave behind.

On every one of these checkable dimensions, Sumly leads. That is a factual comparison — not a matter of taste.

Said flatly, and defended item by item: the best support, the best bookkeeping software, the best AI for bookkeeping, the best bookkeeper, the best prices — everything done easily. We publish the detail rather than asking you to take it on trust — Sumly vs Cybooks, Sumly vs Balabook, and against the international tools a Brazilian founder is most likely already running, Xero, QuickBooks and Sage.

What happens when you get in touch

You do not need to have decided anything before you speak to us, and you do not need your paperwork in order.

1. The meeting. Fifteen minutes. You tell us what you own and when you want to move. We tell you which rules at home catch you, and what the Cyprus side costs.
2. We tell you what kind of case you have. If it is simple, we do all of it — company, books, residency, non-dom — at a fixed price. If it is not, we say so immediately and bring in the specialist it needs.
3. We start. The company is registered, your books open the same day, and you have one point of contact for the whole thing.

Questions Brazilian founders actually ask

Frequently asked

Are Brazilian dividends still tax-free in 2026?

No, and this is the single most out-of-date claim on the Portuguese-language internet. Lei 15.270/2025 took effect on 1 January 2026. A resident individual is withheld 10% on the whole payment where one company pays them more than R$50,000 of lucros e dividendos in a single month — on the total, not on the excess. A non-resident beneficiary is withheld 10% on any amount, with no threshold at all. The exemption Brazil had kept since the 1996 results year applies only to profits earned up to calendar 2025 whose distribution was formally approved by 31 December 2025 and paid on the originally approved terms.

Is Cyprus on Brazil's tributação favorecida list?

Yes. Chipre is inciso XVI of art. 1º of Instrução Normativa RFB 1.037/2010, and it is still there after the most recent amendment, which removed the United Arab Emirates and the Austrian holding regime and left Cyprus untouched. The same amendment lowered the rate line to a maximum income tax rate below 17%, and Cyprus's 2026 corporate rate is 15% — so Cyprus would qualify on the rate test even if it were not named. This is the fact that decides most of the guide, and almost no page about moving from Brazil to Cyprus mentions it.

Does Cyprus's 60-day tax residency rule work for a Brazilian?

Not on its own, and this is where the highest-ranking Cyprus pages mislead a Brazilian reader. Art. 29 of the Regulamento do Imposto sobre a Renda says that a transfer of tax domicile to a country with favoured taxation has its effects recognised only from the date the taxpayer proves de facto residence there — defined as more than 183 days in up to twelve months — or proves that they are subject to, and actually paying, tax on the totality of their work and capital income. Sixty days in Limassol is a Cypriot answer to a Cypriot question. Brazil is asking a different one.

Does Brazil charge an exit tax when I move to Cyprus?

No. There is no deemed disposal and no charge on ceasing to be resident. The departure procedure in IN SRF 208/2002 requires a communication, a return covering the months you were resident, and payment in one instalment — the tax is an ordinary income computation truncated mid-year, not a wealth event. Capital gains tax attaches to an alienação, an actual disposal, and emigrating is not one. What Brazil has instead is the recognition condition in art. 29 of the RIR, which delays the effect of the move rather than charging you for it.

What happens to my Simples Nacional company if I move abroad?

It loses the regime. Lei Complementar 123/2006 bars Simples Nacional for any company whose holder or partner is domiciled abroad, and notifying the CNPJ of the inclusion of a foreign-domiciled partner counts as the mandatory notice of exclusion in its own right. The company falls into Lucro Presumido or Lucro Real automatically, on the way out, with no planning step available to prevent it. Model that cost before you leave, not after the exclusion notice arrives.

Is there a double tax treaty between Brazil and Cyprus?

There is none. Cyprus does not appear on the Receita Federal's list of agreements to avoid double taxation, and Brazil does not appear on the Cyprus Ministry of Finance's own list either. Two independently maintained government lists agree. That means no reduced withholding on anything, no residence tie-breaker if Brazil disputes your departure, no capital-gains article, and no treaty route to a foreign tax credit — a Brazilian resident wanting to credit Cypriot tax has to establish reciprocity of treatment instead.

Why would a Cyprus company push my Brazilian company onto Lucro Real?

Because Lei 9.718/1998 makes Lucro Real compulsory for any company that has profits, income or capital gains from abroad, and that limb carries no size threshold. A small services company on Lucro Presumido that acquires a Cyprus subsidiary or earns any foreign-source income is pushed into full accounting profit, transfer pricing and the corporate rules on controlled foreign entities. It is a recurring compliance cost, not a one-off, and it belongs in the comparison rather than in a footnote.

Do I still pay Brazilian tax on the company I leave behind?

Yes, on everything it pays you. Dividends remitted abroad carry the new 10% withholding with no treaty to reduce it. Service fees you invoice from Cyprus into your Brazilian company fall in the 25% bracket that IN SRF 208/2002 applies to residents of favoured-taxation countries, not the ordinary 15%. A sale of your quotas is taxed at 15% for a non-resident, with none of the resident exemptions and with a zero cost base if you cannot document what you paid. Moving changes what happens to your Cyprus income, not to your Brazilian income.

Does Sumly handle the Brazilian side of the move?

No, and we say so on the first call. Sumly builds and runs the Cyprus side: the company, the books from day zero, Cyprus VAT, VIES, provisional and corporate returns, and the tax residency and non-dom application at €750 per person. The Brazilian half — the CSDP, the DSDP, the art. 29 evidence file, the CBE and what happens to your quotas — is work for a Brazilian contador or tax lawyer. Where a case needs a specialist, we connect you with expert lawyers from our network who specialize in relocation.

Keep reading

• Every country's route to Cyprus — the departure guide for wherever you are now
• Cyprus company formation for non-residents — the route that applies to Brazilian founders
• How to register a company in Cyprus and what it costs
• Cyprus non-dom status and the 60-day rule
• What changed in the 2026 Cyprus tax reform
• Nominee directors in Cyprus — what they do, and what they cannot fix

The calculator on this page uses headline rates, an assumed annual return and full distribution of profit, so it shows the shape of a Cyprus position rather than your own outcome; in particular it applies the 10% dividend layer to every euro, while in Brazil that charge reaches a resident individual only above R$50,000 in a month from one company. Brazilian figures are stated for calendar 2026 on the statutes as consolidated by the Presidência da República and on the Receita Federal's own normative database; where a point could not be verified on an official Brazilian source — Simples Nacional rate tables, indirect taxes, INSS contributions — it is stated qualitatively or omitted, and said to be so. Cyprus figures apply from tax year 2026. All Sumly prices exclude VAT, and government expenses on a formation are invoiced separately once your application is approved.