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Compliance & Regulation

Hiring a Remote Team Abroad: Taxes, FX and Labor Rules

•8 min read•Autor verificado.•Updated on

Quick answer

Paying a professional abroad is an import of services: the general rule is 25% IRRF (Law 9,779/1999), with PIS/Cofins-Importação of 1.65% and 7.6% in 2026 and, in technical contracts, a 10% CIDE. Subordination with salary moves the relationship toward employment under the CLT, art. 3.

IRRF on services remitted abroad
25%general rule
PIS-Importação on services
1.65%
Cofins-Importação on services
7.6%
CIDE on technical services and royalties
10%
Repeal of arts. 1 to 20 of Law 10,865
January 1, 2027
Imagem ilustrativa: Hiring a Remote Team Abroad: Taxes, FX and Labor Rules

Paying a professional who lives abroad is an import of services. Under the general rule, the remittance bears 25% IRRF (withholding income tax, Law 9,779/1999), may trigger PIS/Cofins-Importação of 1.65% and 7.6% in 2026 and, in technical contracts, a 10% CIDE. If there is subordination and salary, the risk is an employment relationship under the CLT (Brazil's Consolidated Labor Laws), art. 3.

This guide covers the Brazilian side: remittance taxes, foreign exchange and the line between contractor and employee. Tax treaties, the law of the professional's country and the choice of intermediary platforms require an analysis of your case by an accountant and a lawyer.

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Is the professional abroad a self-employed contractor or an employee?

What decides it is the reality of the relationship, not the name of the contract. The CLT defines an employee as an individual who provides services of a non-occasional nature to an employer, under the employer's direction and in exchange for pay (art. 3). The employer is the company that assumes the risks of the business and hires, pays and directs the personal provision of service (art. 2).

The CLT also provides that engaging a self-employed contractor, once the legal formalities are met, with or without exclusivity and on a continuous basis or not, rules out employee status under art. 3 (art. 442-B). That does not shield contracts that work as employment in practice.

Element of art. 3Check question
IndividualDoes the contractor work personally, or deliver the result through their own team?
Non-occasional natureIs the work a permanent part of the company's routine or a defined project?
DependenceWho sets the schedule, method and day-to-day orders: the client or the professional?
PayIs payment fixed and periodic, or tied to deliverables and results?

The more answers point to dependence and fixed pay, the greater the risk that the relationship is treated as employment. This classification should be made by a labor lawyer before hiring.

What taxes apply to remittances paying a team abroad?

Paying for services to a resident abroad can trigger three Brazilian taxes, each with its own trigger. The table summarizes what the laws say.

TaxWhen it appliesRateLegal basis
IRRFIncome from work, with or without an employment relationship, and from services remitted to a resident abroad25% (general rule)Law 9,779/1999, art. 7
PIS/Cofins-ImportaçãoPayment, credit, delivery, use or remittance of amounts to a resident abroad as consideration for services rendered1.65% (PIS) and 7.6% (Cofins)Law 10,865/2004, arts. 3, II, and 8, II
CIDELegal entity party to contracts for technical services, administrative assistance and similar with a resident abroad, plus royalties and technology transfer10%Law 10,168/2000, art. 2

A few points to get the calculation right:

  • •IRRF: the law sets 25% for work and services remitted abroad. Tax treaties and other rules may change the treatment, so confirm the specific case before remitting. Law 9,779/1999 also applies 25% to income paid to a beneficiary in a country that does not tax income or taxes it at less than 20% (art. 8).
  • •PIS/Cofins-Importação: the base is the amount paid, credited, delivered, used or remitted, before income tax withholding, plus ISS (municipal services tax) and the contributions themselves (art. 7, II).
  • •CIDE: only legal entities pay it. Whether the team provides technical services or administrative assistance depends on what the contract says, and that classification should be validated by an accountant.

From January 1, 2027, Complementary Law 214/2025 repeals arts. 1 to 20 of Law 10,865/2004, and the import of services is handled under the IBS and CBS regime, which the same complementary law governs. In 2026, the rules above are still in force.

What does Law 14,286 require to send the payment?

Foreign exchange transactions can be carried out freely, with no limit on amount, subject to the law and to Central Bank regulation (Law 14,286/2021, art. 2). They can only be carried out by institutions authorized by the Central Bank to operate in the foreign exchange market (art. 3).

The institution is responsible for identifying and qualifying clients and for the lawful processing of transactions. Classifying the purpose of the transaction, however, is the client's responsibility (art. 4, § 2). In practice, describing the payment as a service, with a contract and invoice to support it, avoids problems with the institution and with the tax authorities.

If you keep an account abroad to receive and pay, you will find the context in offshore bank accounts for Brazilians.

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What steps should you follow before hiring?

Follow the steps in this order, because each depends on the previous one:

  1. •Define the nature of the relationship: self-employed contractor or employee, based on the elements of art. 3 of the CLT.
  2. •Choose who hires: the individual, the Brazilian company or an entity abroad. Each option changes who pays and which taxes apply.
  3. •Calculate the remittance taxes: IRRF, PIS/Cofins-Importação and, where applicable, CIDE, before setting the contract amount.
  4. •Document the payment: written contract, description of the service, invoice and proof of the exchange transaction.
  5. •Review with an accountant and a lawyer: the applicable treaty, the law of the professional's country and any labor classification.

If the hiring goes through an entity abroad controlled by a Brazilian, the controlled-company profit rules of Law 14,754/2023 and the enforcement requirements also come into play. See how Receita enforcement of offshore structures works and the jurisdiction page for Delaware or Wyoming.

What about intermediary platforms, such as EORs?

Platforms that hire the professional abroad on the client's behalf exist, but this guide does not compare names or prices: there is no official source to support such a comparison. What the law lets us state is narrower. If the platform or the professional is a resident abroad, the payment to them is a remittance to a resident abroad as consideration for services (Law 10,865/2004, art. 3, II). The contract with the platform must be read in light of the rules above.

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hiring a remote team abroadpayment for imported services BrazilIRRF on remittances abroadPIS/Cofins-Importação servicescontractor or employee CLT

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Dr. Heitor Miguel

Attorney registered at OAB/SP 252,633. MBA in Business Law and M&A from FGV. Specialist in International Law and iGaming. President of the International Law Commission at OAB/SBC. Deal Maker of the Year 2014 – IAE Awards.

Tax PlanningComplianceInternational LawiGaming
Do I need to withhold tax when paying a freelancer abroad?

The general rule is 25% IRRF on income from work, with or without an employment relationship, and from services remitted to a resident abroad (Law 9,779/1999, art. 7). Treaties and other rules may change the treatment, so confirm the case before the remittance.

Does PIS/Cofins-Importação apply to services hired abroad?

Yes. The taxable event includes payment, credit, delivery, use or remittance of amounts to a resident abroad as consideration for services rendered, with rates of 1.65% (PIS) and 7.6% (Cofins) on the base defined by law (Law 10,865/2004, arts. 3, 7 and 8).

Does CIDE apply to every payment abroad?

No. The contribution is owed by the legal entity party to contracts for technology transfer, technical services, administrative assistance and similar with a resident abroad, and to royalties, at a 10% rate (Law 10,168/2000, art. 2). The classification depends on the subject of the contract.

Does hiring a foreign company eliminate the risk of an employment relationship?

No. The CLT looks at the facts: an individual, a service of a non-occasional nature, dependence and pay (art. 3). Engaging a self-employed contractor with the legal formalities rules out employee status (art. 442-B), but it does not protect a relationship that works as employment in practice.

Can I send any amount abroad to pay the team?

Law 14,286/2021 allows foreign exchange transactions with no limit on amount, but they must be carried out by an institution authorized by the Central Bank, and the purpose of the transaction is classified by the client (arts. 2, 3 and 4, § 2). The remittance taxes are still due.

What changes in remittance taxation in 2027?

Complementary Law 214/2025 repeals, from January 1, 2027, arts. 1 to 20 of Law 10,865/2004, which deal with PIS/Cofins-Importação, and the import of services moves to the IBS and CBS regime. Follow the regulations before closing contracts that straddle the new year.