FSC Tax Consultant — Strategic clarity for cross-border tax decisions

What We Do

Specialized Brazilian tax advisory for individuals and cross-border cases.

Technical, conservative, and individually tailored advisory across the full lifecycle of cross-border tax matters in Brazil. Each engagement is structured around the client's specific situation, residency status, and international footprint.

Expat Tax Compliance in Brazil

For foreign individuals who are tax residents in Brazil. Scope: annual individual income tax return (DAA), monthly Carnê-Leão, foreign income reporting, foreign tax credit analysis under applicable treaties, and asset and rights disclosure (Bens e Direitos).

Tax Residency and Exit Planning

For individuals entering or leaving Brazil. Scope: Brazilian tax residency rules, the 183-day rule, visa-based residency triggers, the Definitive Departure Communication (CSDP), the Final Departure Tax Return (DSDP), and tax planning before any change of residency status.

Foreign Investments and Offshore Taxation

For Brazilian tax residents with assets abroad. Scope: the regime introduced by Law 14,754/2023 for foreign financial investments, controlled foreign entities, and trusts; annual taxation of profits; reporting obligations; and technical analysis under the new rules.

Shadow Payroll and Expat Compensation

For multinational companies with expatriates in Brazil. Scope: shadow payroll setup, gross-up calculations, tax equalization and tax protection policies, hypothetical tax design, and coordination between home and host payrolls.

Brazil Tax for Returnees

For Brazilians returning to the country after a period abroad. Scope: reacquisition of Brazilian tax residency, treatment of foreign assets and offshore structures, pre-return planning, and post-return reporting obligations.

Corporate Mobility Tax Advisory

For companies managing inbound and outbound assignments. Scope: assignment tax planning, employer and employee obligations, expatriate compliance calendars, and risk management for cross-border workforces.

Banco Central Reporting (CBE)

For Brazilian residents holding assets abroad above the regulatory threshold. Scope: the annual and quarterly Brazilian Capital Abroad Declaration (Declaração de Capitais Brasileiros no Exterior — CBE), filing requirements, deadlines, and exposure to penalties for omission or inaccuracy.

Why FSC Tax Consultant

Big Four depth, boutique attention.

We combine the technical depth typically expected from large international professional services firms with the personalized attention of a boutique advisory practice — bringing deep knowledge of Brazilian tax law with a global perspective.

Deep specialization in individual taxation and global mobility
International experience aligned with Big Four standards
Direct access to a senior advisor on every engagement
Conservative, risk-aware analysis grounded in Brazilian tax law
Clear communication for international clients

Fernando Castelo

Founder · FSC Tax Consultant

Fernando Castelo is the founder of FSC Tax Consultant, an international tax advisory boutique specialized in Brazilian individual taxation, global mobility, and cross-border compliance.

His practice focuses on the most technically demanding individual tax matters in Brazil: tax residency, definitive departure, expatriate compensation, foreign investments, offshore structures, trusts, and the application of double tax treaties.

Fernando advises a focused client base across the most complex individual and corporate mobility matters in Brazil — from foreign executives and their families relocating to the country, to Brazilians managing the final departure return, individuals with offshore structures and foreign investment portfolios, multinational companies coordinating expatriate assignments, and HR and Global Mobility teams structuring shadow payroll, gross-up, and tax equalization arrangements.

His work combines the standards expected from large international consulting firms with the agility, discretion, and direct attention of a specialized boutique.

Technical depth

Every analysis is grounded in Brazilian tax legislation, official guidance from Receita Federal — including Soluções de Consulta and Pareceres Normativos COSIT — Banco Central do Brasil regulations, and applicable double tax treaties.

Global perspective

Brazilian tax matters rarely exist in isolation. We design solutions that operate in coordination with foreign jurisdictions and reflect international best practices in mobility and compliance.

Personalized advisory

Clients work directly with a senior advisor. No handoffs, no junior-only delivery, no generic answers.

Contact

Let's discuss your case.

Every tax position in Brazil requires individual analysis. We work with clients worldwide and respond personally to every inquiry.

Direct contact

Email
contact@fsctaxconsultant.com

Practice scope
Based in Brazil — serving clients globally. Remote international advisory available. Consultations conducted in English via video call. All documentation handled digitally.

Response time. Inquiries are reviewed personally and typically receive a first response within one business day.

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Strategic clarity for cross-border tax decisions

Individuals and companies navigating Brazilian tax from an international perspective.

Specialized Brazilian tax advisory for individuals and cross-border cases.

Big Four depth, boutique attention.

Fernando Castelo

Brazil Tax Pocket Guide 2026

Every tax position in Brazil requires individual analysis. Let's discuss your case.

Let's discuss your case.