Art, Cars and Jewelry Abroad: Rules for Brazilians in 2026

A Brazil resident can hold art, cars or jewelry through a structure abroad, but the asset does not leave Brazil's radar. The stake or the assets go on the income tax return, the Central Bank receives the CBE if the total abroad reaches US$ 1,000,000.00 on December 31, and an inheritance may be subject to ITCMD.

The CBE is the Brazilian Capital Abroad report, and ITCMD is the state inheritance and gift tax.

Who reports luxury assets that stay outside Brazil?

Anyone who is a tax resident of Brazil reports them. It does not matter whether the painting sits in a vault in Geneva or the car sits in a garage in Florida. Resolution BCB 279 of the Central Bank of Brazil defines Brazilian capital abroad as "amounts, goods, rights and assets of any nature held outside the national territory by residents." Works of art, cars and jewelry fall under that definition when they are outside the country.

The structure changes how the asset appears, not whether it appears. Here are the two most common paths:

For the DAA step by step, see how to report offshore assets on your income tax return.

Does a company abroad holding art or cars become a "controlled entity" for Brazil's Federal Revenue Service (Receita Federal)?

It becomes a controlled entity if you hold the upper hand in decisions or more than 50% of the capital or of the rights to profits, alone or with related persons. That is what art. 5, § 1, of Law 14,754/2023 says. Funds and foundations also fall under this definition.

The point of attention is the controlled entity's profit. It is taxed on December 31 of each year, at the 15% rate of art. 2, when the entity:

• •is in a country with favored taxation or has a privileged tax regime (arts. 24 and 24-A of Law 9,430/1996); or
• •earns own active income below 60% of total income.

That second test matters for collectors. Art. 5, § 6, excludes rents and capital gains from own active income, except for the sale of a permanent asset acquired more than two years earlier. An LLC that only rents out collector cars, or frequently resells pieces, may fall in as a passive controlled entity. One that only holds the asset and has no revenue generates no profit to tax, but the stake is still reported.

If you prefer to report the entity's assets as if they were your own, art. 8 allows that option. It applies per entity and is irrevocable and final for as long as you hold it. With individual partners who live in Brazil, all of them must opt in.

Anyone using an LLC can compare the Wyoming and Delaware models, but the choice of U.S. state does not change the Brazilian controlled-entity rule.

Do you have to tell the Central Bank about art, cars and jewelry abroad?

Yes, if total Brazilian capital abroad reaches US$ 1,000,000.00 or more on December 31. Art. 10 of Resolution BCB 279 sets that threshold for the annual report (CBE). The amount is the sum of everything you hold outside the country, not just the luxury items.

Two practical points:

• •The resolution implements Law 14,286/2021, the foreign exchange framework, and applies to assets of any nature held by residents. If the structure is a company, the stake in it counts toward the total.
• •Art. 3, sole paragraph, requires keeping the documentation that proves the capital for 10 years from the completion of the transaction. Purchase invoice, appraisal report, insurance policy and custody agreement should be kept organized.

The Central Bank maintains the official CBE page with deadlines and the filing system. Check the year's calendar there.

How does ITCMD reach luxury assets abroad?

Authority belongs to the States and the Federal District, which institute the tax on "transfer upon death and gifts, of any goods or rights" (Constitution, art. 155, I). For movable property such as art, cars and jewelry, § 1, II, points to the State of the deceased's or donor's domicile.

When there are assets abroad, § 1, III, says authority will be regulated by complementary law if the donor is domiciled abroad or if the deceased owned assets, was a resident or had probate processed outside the country. Item IV of § 1 leaves the maximum rates to the Senate, and item VI, added by Constitutional Amendment 132/2023, provides that the tax will be progressive according to the value of the share, legacy or gift.

In practice, what you have to do is:

1. •Check your State's law on how ITCMD treats assets abroad, because the local rule changes the result.
2. •Not assume that the offshore company eliminates the tax. What changes is that the asset becomes the stake in the company instead of the work itself.
3. •Plan succession in advance. The articles on offshore succession and probate and international gifts detail the paths.

For a trust, Law 14,754/2023 (art. 10, § 2) treats the change of ownership as a gift, if it occurs during life, or as a transfer upon death, if it results from the settlor's death.

What happens if the car, the artwork or the jewelry comes to Brazil?

It enters as a foreign good, and importation may carry taxes. Brazil's Federal Revenue Service states that the Import Tax applies to foreign goods, with the customs value as its calculation base and a rate set in the Common External Tariff (TEC), which depends on the classification of the item. The exact rate varies by product, which is why this article gives no percentage.

Before shipping or bringing it in luggage:

• •Ask a customs broker for the item's tax classification (NCM). A collector car, a canvas and a watch have different classifications.
• •Confirm on the official Import Tax page and in the Customs Manual whether there are other taxes or licenses for that item.
• •Keep the purchase invoice and proof of origin. They support the customs value and the reporting of your assets.

If the asset is held by a company abroad and you bring it in for personal use, treat it as an import, not as a "change of address" for the asset.

Does the offshore structure protect assets or just change the paperwork?

It separates the asset from your name, which helps with organization, custody and succession. It does not eliminate the duty to report and does not keep scrutiny away. For anyone who wants to isolate risks, the article on asset segregation with LLC, trust and holding compares the formats.

A few precautions apply to any collection:

• •Clear ownership. Whoever appears on the car's registration, the artwork's certificate or the jewelry's invoice must be the entity or you, not a "trusted" third party.
• •Insurance and appraisal in the right name. The policy and the appraisal report must follow the asset's owner.
• •Personal use. If the company owns the car and you drive it every day, the separation between individual and legal entity becomes fragile. Document the use and consult your accountant.
• •Information exchange. The CRS covers financial accounts, not physical assets. Even so, the bank account of the structure that pays insurance or receives the sale may be reported to the Federal Revenue Service. See CRS and automatic exchange of tax information.

To set up the structure with tax suitability, the OffshoreProz team works on tax planning and corporate structures.