The Brazilian government published Decrees 12.666 and 12.667 on 11 November 2025, bringing into force two landmark agreements with India: an Agreement on Cooperation and Facilitation of Investments (ACFI) effective 21 December 2025 and an updated Protocol to the Brazil–India Double-Taxation Treaty, already effective since 18 October 2025.
Key features – The ACFI introduces institutional dialogue channels and mediation to resolve investor disputes, giving companies clearer timelines to obtain work permits, environmental licences and foreign-exchange approvals. The revised tax protocol aligns withholding-tax rates on dividends, royalties and technical services with OECD norms—reducing the maximum tax on service-fee remittances from 25 % to 15 %.
![Brazil Promulgates Investment and Tax Treaties With India, Easing Expat Assignment Costs]()
Mobility impact – Indian multinationals in IT, engineering and pharmaceuticals, which together deploy more than 3 000 specialists to Brazilian projects annually, stand to benefit from lower gross-up costs on cross-border allowances. Conversely, Brazilian firms sending managers to Indian joint ventures will find income-tax crediting easier under the new article 23, cutting double-tax exposure. Global-mobility teams should also revisit assignment cost projections: KPMG estimates an average saving of US $8 500 per employee per year on Brazilian payrolls once the new withholding rates apply.
Strategic context – The pacts deepen a South-South partnership that has accelerated since both countries joined the OECD Inclusive Framework. They follow the signing of a Customs Operator (OEA) mutual-recognition work plan last month and precede a BRICS mobility dialogue set for February 2026 in New Delhi.
Action points – Companies should: (1) update tax-equalisation policies; (2) review inter-company service contracts for the lower withholding rate; (3) monitor forthcoming rules from Brazil’s Receita Federal on documentary proof required to claim treaty benefits at source.
Key features – The ACFI introduces institutional dialogue channels and mediation to resolve investor disputes, giving companies clearer timelines to obtain work permits, environmental licences and foreign-exchange approvals. The revised tax protocol aligns withholding-tax rates on dividends, royalties and technical services with OECD norms—reducing the maximum tax on service-fee remittances from 25 % to 15 %.
Mobility impact – Indian multinationals in IT, engineering and pharmaceuticals, which together deploy more than 3 000 specialists to Brazilian projects annually, stand to benefit from lower gross-up costs on cross-border allowances. Conversely, Brazilian firms sending managers to Indian joint ventures will find income-tax crediting easier under the new article 23, cutting double-tax exposure. Global-mobility teams should also revisit assignment cost projections: KPMG estimates an average saving of US $8 500 per employee per year on Brazilian payrolls once the new withholding rates apply.
Strategic context – The pacts deepen a South-South partnership that has accelerated since both countries joined the OECD Inclusive Framework. They follow the signing of a Customs Operator (OEA) mutual-recognition work plan last month and precede a BRICS mobility dialogue set for February 2026 in New Delhi.
Action points – Companies should: (1) update tax-equalisation policies; (2) review inter-company service contracts for the lower withholding rate; (3) monitor forthcoming rules from Brazil’s Receita Federal on documentary proof required to claim treaty benefits at source.
