Você sabe o que é tributação offshore? Acesse o artigo da Arbrent e conheça as principais mudanças aprovadas pelo Senado Federal em dezembro de 2023.

O que é tributação offshore?

A cobrança de tributação offshore é realizada quando um brasileiro possui rendimentos e bens no exterior. Recentemente, o Senado Federal aprovou um projeto de lei que altera as alíquotas desses impostos, mas você entende o que é tributação offshore?

O que é tributação offshore?

O assunto de hoje no blog da Arbrent é o que é tributação offshore. Este termo, de origem inglesa, remete às diferentes atividades, sobretudo empresariais, realizadas em territórios estrangeiros. Ou seja, impostos cobrados sobre bens e rendimentos no exterior, podendo ser cobrado tanto de Pessoa Física quanto de Pessoa Jurídica.

Entre as principais operações envolvendo o pagamento de tributos offshore estão os investimentos financeiros com aplicações no exterior. Os ganhos de capital, juros e dividendos gerados nessas atividades estão sujeitos à tributação, assim como os lucros obtidos com atividades empresariais.

Contudo, as empresas cuja constituição se dê em países onde a tributação é menor que no Brasil (os chamados paraísos fiscais) devem realizar o pagamento de tributação offshore proporcional. Esta é uma forma de equilibrar o desenvolvimento financeiro do país. 

Vale ressaltar que o pagamento é obrigatório, ainda que o devedor já tenha pagado a tributação no país em que os rendimentos foram gerados.

Entenda as mudanças de alíquotas

Em dezembro de 2023 o Senado Federal aprovou a mudança de alíquotas para a tributação offshore nos casos de fundos de investimento e renda obtida fora do Brasil através de empresas com sede no exterior. 

Essas mudanças surgem da necessidade de equilibrar as taxações sobre ganhos que não chegam a passar pelo território nacional. Afinal, esse acúmulo gera desequilíbrio fiscal e desigualdades sociais. Afinal, segundo dados do Banco Central, estima-se que os brasileiros têm em torno de 200 bilhões de reais convertidos em ativos no exterior. 

Porém, para pessoas físicas que tenham bens no exterior, existe a opção de atualização para os valores de mercado em 31 de dezembro de 2023 com alíquota de 8% sobre a diferença do valor de compra e o preço atualizado. Alguns itens estão vedados dessa atualização, como jóias e obras de arte. Também estão proibidas mudanças de valores dos bens e direitos vendidos antes das alterações ou que não tenham sido declarados em 2022.

Já as alíquotas de tributação offshore para fundos exclusivos são de 15% para longo prazo e 20% sobre rendimentos de curto prazo (máximo um ano). A cobrança sobre fundos fechados ocorre de maneira cumulativa após finalizado o período de duração. 

Além disso, o texto do PL 4.173/2023 também altera a relação de cobrança de impostos sobre os trusts, ou seja, a transmissão de bens e direitos patrimoniais de empresas geralmente familiares. 

Implicações do não pagamento de tributos

As regras do PL já começam a valer em 2024. Sendo assim, pessoas físicas e jurídicas que possuam bens e direitos no exterior devem se orientar com base nas novas alíquotas, de modo que o pagamento de tributos ocorra da maneira adequada.

A não observância dessas alterações pode gerar desgastes fiscais como multas por atraso, onerosidade na condução de negócios e dificuldade na administração de rendimentos e finanças.

A Arbrent possui as melhores práticas para a execução de funções tributárias. Acesse o site para saber mais!

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