Offshore Dropshipping for Brazilians: Taxes and Imports

Dropshipping through a company abroad does not take you out of Brazilian law's reach. If you are a tax resident in Brazil and control the company, Law No. 14,754/2023 (Lei 14.754/2023) brings the profits into your individual income tax (IRPF): on December 31 or when made available. Selling to customers in Brazil also triggers import rules.

This guide covers the Brazilian side for anyone selling online through a company outside the country. It does not promise tax savings and has no cost table: none of the official sources below sets a price for opening or maintaining a company, so ask the provider for a quote and compare it with your accountant's. For recurring subscriptions, see the offshore subscription box guide.

How does Law 14,754 tax a dropshipping company based abroad?

A company you control abroad is a "controlled entity" when you have the power to decide in deliberations, to elect most of the directors, or hold more than 50% of the capital or profits, alone or with related persons (art. 5, § 1). Earnings go into the Annual Adjustment Return (DAA) separate from other income, at a 15% rate on the annual amount and with no deduction from the base (art. 2, § 1).

What changes is the timing of taxation:

The law also treats as made available any credit operation between the controlled entity and you, or a related person, if it has profits or profit reserves (art. 6, sole paragraph, II). Lending the company's money to the partner is therefore not a safe way to defer the tax.

What is "own active income" and why does it matter for online sellers?

Own active income is the revenue the controlled entity earns directly by carrying on its own economic activity. The law excludes from that concept revenue arising exclusively from royalties, interest, dividends, equity interests, rents, capital gains (except permanent assets held for more than 2 years), financial investments and financial intermediation (art. 5, § 6, I). Total income is the sum of all revenue, including non-operating revenue (art. 5, § 6, II).

Revenue from the sale of goods does not appear on this exclusion list. That does not mean your company is automatically outside the December 31 rule: the classification depends on the facts, such as interest on invested cash and the jurisdiction chosen. Ask an accountant with Law 14,754 experience for an analysis before opening the company.

When is the company's jurisdiction "favored taxation" for the Federal Revenue Service?

Law No. 9,430/1996 (Lei 9.430/1996) defines, in art. 24, a favored-taxation country as one that does not tax income or taxes it at a maximum rate below 17%. The official list of countries and dependencies is in art. 1 of IN RFB 1.037/2010, and privileged tax regimes are in art. 2. In the version I checked, as amended by IN RFB 2.265/2025, the list includes, for example, the British Virgin Islands and Seychelles.

Do not assume based on a country's reputation. Open the current rule on the Federal Revenue Service website and check the jurisdiction before forming the company, because the list is changed by new normative instructions. For the specific case of a US LLC, this page has no official source on how the Federal Revenue Service classifies it, so the conclusion must come from your accountant, not from a generic guide.

How does importing work when I sell to consumers in Brazil?

When the order leaves abroad for a Brazilian consumer, it is an import. The Federal Revenue Service states that the general rule is 60% Import Tax plus state ICMS, and that international purchases are always subject to taxes. The Remessa Conforme Program (PRC) certifies e-commerce companies that adopt differentiated import rules: the buyer pays the taxes at the time of purchase, not when the package arrives.

According to the Federal Revenue Service page "Quanto vou pagar de impostos?" ("How much tax will I pay?"), updated on September 14, 2026, the Import Tax works as follows:

The purchase value for the calculation is product plus freight plus insurance. ICMS is calculated "from the inside," including the Import Tax in the base, and each State's rate is in a Comsefaz table indicated by the Federal Revenue Service; the official calculator uses 17% as a reference. Certified sites must show, on each product page, that it comes from abroad, that it will be imported and the total amount charged, itemizing product, freight, insurance, Import Tax and ICMS.

The Federal Revenue Service updates these pages, and the one I used is dated September 14, 2026. Before setting your final price, open the Remessa Conforme Program page, check the update date and use the tax calculator on the Portal Compras Internacionais.

Do I need to declare the company and the accounts abroad?

Yes, on two different fronts.

1. •Income tax (DAA): the resident declares separately the earnings on capital invested abroad, including profits and dividends of controlled entities (Law 14,754, art. 2). Profits taxed on December 31 go on the assets and rights schedule as the cost of the dividend credit receivable, with the year of origin (art. 5, § 10, IV).
2. •Declaration of Brazilian Capital Abroad (CBE): BCB Resolution 279/2022 calls Brazilian capital abroad the amounts, goods, rights and assets of any nature held outside the country by residents (art. 1). The information to be provided includes, among others, the stake in the capital of nonresident companies and deposits in nonresident institutions (art. 7, I and VI). The annual declaration is due when the total on December 31 reaches US$ 1,000,000 or more (art. 10); the quarterly one, when it reaches US$ 100,000,000 or more on the quarterly reference date (art. 11).

CBE deadlines and penalties are on the Central Bank's CBE page. Below the US$ 1,000,000 threshold, the CBE is not required, but the DAA still is.

What is IRS Form 5472 and when does it apply to the dropshipper's LLC?

Form 5472 is an IRS information return for the "reporting corporation": a US corporation with 25% or more foreign ownership, including a domestic disregarded entity wholly owned by a foreign person. The one who must file is the entity that had a reportable transaction with a related party, such as the foreign owner themselves.

According to the IRS instructions:

• •a disregarded entity with a foreign owner has no income tax return obligation of its own, but must file a pro forma Form 1120, with Form 5472 attached, by that form's deadline;
• •the penalty for failing to file the form on time and in the proper form is US$ 25,000;
• •if the failure continues for more than 90 days after IRS notification, there is an additional US$ 25,000 penalty per related party for each 30-day period.

Form 5472 is a US obligation, independent of the DAA and the CBE in Brazil. If your design uses a US LLC, put the deadline on your accountant's calendar from the first year, even if the company had little activity.

In what order should you structure offshore dropshipping?

1. •Define the design before opening the company: who the owner is, in which country, and who receives the profit. This decides the classification under Law 14,754.
2. •Check the jurisdiction in IN RFB 1.037/2010 and Law 9,430/1996, art. 24.
3. •Plan the cash flow: account opening and receiving payments. See the offshore banking service and the multi-currency strategy for Brazilians.
4. •Define logistics and import: does the Brazilian customer pay at purchase (PRC) or when the package arrives?
5. •Build the obligations calendar: DAA, CBE and, if there is a US LLC, Form 5472.
6. •Look after customer data protection: the GDPR and LGPD guide for offshore companies covers the topic.
7. •Validate everything with your accountant in tax planning and compliance.