Best Countries to Open an Offshore Company in 2026: Comparison

No single country is the best for everyone. For people who are tax residents of Brazil, tax on foreign profits and income follows Law No. 14,754/2023 (Lei 14.754/2023), and the country you pick affects how Brazil's Federal Revenue Service (Receita Federal) classifies the company, your reporting duties and your access to a bank. This comparison uses official sources only.

What Is the Best Country to Open an Offshore Company as a Brazilian?

It depends on your goal and on what the bank accepts. No official source publishes a ranking of jurisdictions, so this article gives no score or position. What can be compared safely is how Brazil treats each place and what Brazilian law requires after you open the company.

The choice starts with the goal: investing in the US, protecting assets, organizing succession or running a business. Setup and maintenance costs vary by provider and by year, so they are left out of the comparison and should be requested together with the current official fee table of each jurisdiction. If you are still building your plan, start with our international tax planning service.

How Does Law 14,754/2023 Treat a Company Abroad?

The law sets a 15% income tax (IRPF) rate in the annual adjustment on financial investment income and on profits and dividends of entities controlled abroad, with no deduction from the tax base (art. 2, § 1). A controlled entity is one where you have the upper hand in decisions, the power to elect most of the managers, or more than 50% of the capital or of the rights to profits (art. 5, § 1).

The country matters because of the timing of taxation. A controlled entity's profits are taxed on December 31 of each year, without any remittance, when it is in a favored-taxation country, has a privileged tax regime, or earns active income of its own below 60% of its total income (art. 5, caput and § 5). Other controlled entities are taxed when the profit is actually made available to you (art. 6, II). Those in this second group may opt for annual taxation (art. 6-A).

This criterion applies to any country. A holding company that only receives dividends, interest or rent can fall under the 60% rule even in a jurisdiction that is not classified as favored.

How Does the Receita Federal Classify the US, BVI, Cayman, Nevis and Uruguay?

The classification is in RFB Normative Instruction 1,037/2010 (Instrução Normativa RFB 1.037/2010), which lists the favored-taxation countries (art. 1) and the privileged tax regimes (art. 2). The table shows what the current text says about each jurisdiction and the effect under Law 14,754/2023.

Three cautions when reading the table. The list changes: IN RFB 2,265/2025 amended art. 1 and moved the rate criterion to below 17%, so always check the version currently in force. Fitting an LLC into art. 2, VII depends on how it is taxed in the US, and that requires an accountant's analysis. And classification does not mean prohibition: it only defines when Brazilian tax applies.

For details on each location, see the pages for Delaware, Wyoming, BVI, the Cayman Islands and Nevis.

Which Obligations Apply to Any Jurisdiction?

Five obligations come with the structure, whatever the country.

The first is the Annual Adjustment Return: income and profits from abroad go in a field separate from the rest (Law 14,754/2023, art. 2). The second is the Declaration of Brazilian Capital Abroad (CBE) filed with the Central Bank of Brazil (BCB). The annual CBE is mandatory for anyone with assets abroad totaling US$ 1 million or more on December 31, filed from February 15 to April 5 of the following year. The quarterly version requires US$ 100 million. The Central Bank reports fines from BRL 2,500 to BRL 250,000 for those who fail to file, with the possibility of a 50% increase in some cases.

The third is information exchange. IN RFB 1,680/2016 requires e-Financeira institutions to identify accounts under the Common Reporting Standard (CRS), created by several countries under OECD coordination, and provides for automatic exchange of that information. On the US side, the IRS explains that FATCA requires foreign financial institutions to report the assets of their American clients, and the US Treasury lists a Model 1 intergovernmental agreement with Brazil, in force since June 26, 2015.

The fourth is the BOI. FinCEN reports, in an update dated August 11, 2026, that US companies are exempt from reporting beneficial owners and no longer need to file BOI reports. The fifth is the compliance of the structure itself, which is the subject of our compliance service.

How Do You Choose Between Jurisdictions in Practice?

Start with the goal and confirm each step against Brazilian law. Those who want to invest in American assets usually look at a US LLC, and the classification under art. 2, VII of IN 1,037 must be clear before opening. Those seeking asset protection should understand each jurisdiction's local regime, and our analyses of Nevis and the Cayman Islands cover those cases. For an overview of the topic, read the asset protection guide. If the idea is a hub in Latin America, see offshore in Uruguay.

The bank account is each bank's decision, and no jurisdiction guarantees approval. So treat opening an account as part of the planning from the start. Our offshore banking page explains how that process works, and the corporate structures page shows the possible formats. To understand the steps from start to finish, see how it works.