On July 14, 2025, the Brazilian Federal Revenue Service (RFB) issued Normative Instruction RFB No. 2,271, which revises and expands the procedures for payments, credits, and remittances abroad. The regulation, now in force, establishes new requirements for prior electronic registration and supporting documentation, encompassing nearly all types of international transactions, and imposing significant penalties for non-compliance.
The main innovation is the mandatory prior electronic registration in the RFB (Brazilian Federal Revenue Service) system for any amounts paid, credited, delivered, used, or remitted abroad for expenses related to market research; rental or leasing of stands and venues for exhibitions, fairs, and similar events; and promotion or advertising carried out within the scope of these events, aimed at Brazilian products, services, or tourist destinations. This requirement also applies to service contracts, royalty payments, and other similar transactions, and must be fulfilled before the payment is executed or the foreign exchange settlement is completed. For contracts involving multiple remittances, each installment must be registered individually, which may affect disbursement schedules and contractual provisions.
Taxpayers must retain supporting documentation, including contracts, invoices, payment receipts, and foreign exchange records, in a format suitable for prompt submission during tax audits. In cases where a zero-tax rate applies, such as certain expenses related to commercial promotion abroad, beneficiaries and amounts paid must be individually identified, thereby increasing the level of detail required.
Notably, even payments executed entirely offshore, that is, between foreign accounts of companies within the same corporate group, are not exempt from the registration requirement. Under Law No. 11,371/2006, such operations must also comply with the rules of the National Monetary Council and the RFB regarding reporting and document retention.
Financial institutions authorized to operate in the foreign exchange market are likewise responsible for verifying registration compliance and are prohibited from processing remittances that do not meet the requirements. Penalties include fines of BRL 500 per calendar month for failure to respond to tax summons and 3% of the transaction amount, subject to a minimum of BRL 100, for incomplete or inaccurate information. These penalties may also be enforced against foreign companies through the joint liability of the Brazilian contracting party.
From an international perspective, this regulatory change is strategic. Foreign companies receiving payments from Brazilian clients must anticipate potential delays due to the new mandatory steps and adjust contractual deadlines and payment terms accordingly. Strengthening the exchange of documents and information with Brazilian counterparts will be essential to ensure timely and accurate registration.
Normative Instruction RFB No. 2,271 reflects a global trend toward closer alignment between tax enforcement and foreign exchange monitoring, consistent with international guidelines to combat tax evasion and money laundering. For multinational groups with operations in Brazil, compliance with these rules not only mitigates the risk of penalties but also helps prevent undue tax withholdings and avoid protracted administrative disputes.