Brazilの税務居住ルール：183日テスト
183日のしきい値
Brazilにおける183日ルールの仕組み
Brazil counts 183 days within any 12 month period. Becoming a resident triggers worldwide income taxation.
ローリング12カ月ウィンドウ. これは、暦年の区切りだけでなく、任意の日付から遡って計算されることを意味します。ローリングウィンドウは数字が毎日変わるため、手動での追跡が難しくなります。
183日を超えると、Brazilは税務居住者としてあなたの全世界所得に課税する可能性があります。具体的な影響は、個人の状況、適用される租税条約、所得の種類によって異なります。
日数のカウント方法
How residency starts in Brazil depends on your visa. A permanent visa or residency makes you a tax resident from the day you arrive. Anyone on a temporary visa has 183 days of presence within a rolling 12 month window before residency kicks in. Once you are in, you stay in until you formally file the departure paperwork: the Comunicação de Saída Definitiva, followed by the Declaração de Saída Definitiva. Skip those forms and Brazil keeps treating you as resident even after you have left the country for good.
1日とみなされる条件
Both the day you arrive and the day you leave count. The window is rolling rather than tied to the calendar, so Brazil counts any combination of 183 days inside the prior twelve months.
日数以外の判定基準
For permanent visa holders the day count is beside the point: you are resident from day one. The thing that catches people leaving Brazil is the departure declaration. Without it, the Receita Federal keeps taxing your worldwide income for as long as the paperwork sits unfiled.
特別税制
Brazil has no special regime for incoming expats. Residents pay progressive income tax on their worldwide income, topping out at 27.5%, and can credit foreign tax paid under any applicable treaty.
租税条約
For a country its size, Brazil's treaty network is thin. The most obvious gap is the absence of any income tax treaty with the US. Where treaties do exist, they generally follow the OECD tiebreaker model with some local adjustments.
よくある質問
When does Brazilian tax residency start?
It depends on your visa. A permanent visa makes you resident from your arrival date. With a temporary visa, residency kicks in once you have spent 183 days in Brazil within any 12 month period since you arrived.
What is the departure declaration?
Two forms, filed when you are leaving Brazil for good. The Comunicação de Saída Definitiva is due within 30 days of departure; the Declaração de Saída Definitiva follows in the next year's tax return season. Until both are filed, Brazil keeps treating you as a resident taxpayer.
Is there a tax treaty between Brazil and the US?
Not as of 2026. With no bilateral income tax treaty in place, each side runs its own foreign tax credit, and where the two credits do not line up you can end up paying tax twice on the same income.
公式情報源: https://www.gov.br/receitafederal/pt-br