Investing in Brazil via an LLC: Benefits and Precautions

Published on October 2, 2025 and written by Cyril Jarnias

Investing in Brazil via a SCI: Opportunities and Challenges

In an expanding economic context, Brazil emerges as an attractive investment destination for bold entrepreneurs looking to diversify their real estate portfolio. However, the Brazilian venture is not without its challenges, and the choice of entity through which you invest plays a crucial role.

The Benefits of a SCI for Investing in Brazil

By opting for a Société Civile Immobilière (SCI), investors can benefit from:

• Attractive tax advantages
• Simplified management
• Avoiding the bureaucratic complexities often associated with direct foreign investments

Risks to Consider

Nevertheless, it is essential to be aware of potential pitfalls:

• Exchange rate fluctuations
• Unpredictable local regulations

This article guides you through the benefits and pitfalls of investing via a SCI in Brazil, to equip you with the necessary knowledge to make informed decisions.

Optimizing the Structure for Real Estate Purchase in Brazil

A French SCI can serve as a holding vehicle for shares of a Brazilian entity that purchases the building in Brazil, but it must be structured as a “holding” above a local company compliant with Brazilian law to secure ownership, registration, and taxation.

Common Brazilian Structures for Acquiring the Asset

• Sociedade Limitada (Ltda): Simple, flexible management, well-accepted by banks and notaries, suitable for real estate holdings; requirement to appoint a resident individual administrator in Brazil.
• Sociedade Anônima (S/A): Heavier, costlier governance but useful for major projects or opening to multiple investors; at least two directors required.
• EIRELI/unipersonal alternatives: Historical unipersonal vehicles; depending on local law status, prefer Ltda today for its simplicity and availability.

Role of the French SCI

• Holding the quotas of the Brazilian company (Ltda/S/A).
• Inter-company shareholders’ agreement to lock in governance, distributions, and exits.
• Intra-group agreements (financing, management fees, shareholder loans) compliant with Brazilian foreign exchange and regulations.

Potential Tax Benefits (to be validated per treaties and tax residences)

• Local taxation in Brazil primarily on rental income and capital gains at the Brazilian company level, with potential to optimize via regime choice and intra-group debt structuring, under Brazilian rules.
• Avoidance of double taxation possible when treaties apply; necessary verification for routing dividends/interest to the SCI and their Brazilian withholdings.
• Capitalization and indebtedness: Ltda allows capital contributions or shareholder loans; compliance with ratios, transfer pricing, and required local documentation.

Adaptation to Brazilian Laws and Regulations

• Property transfer only upon registration at the Registro de Imóveis after escritura; essential for enforceability and title security.
• Real estate legal framework: Civil Code (property/contracts), Lease Law (leases), Condominium Law, Subdivision Law; integration of these norms in contracts and due diligence.
• Local administration: appointment of a resident administrator in Brazil and obtaining a compliant address/headquarters per zoning; possibility of temporary domiciliation if permitted.
• Prior compliances: verification of CPF/CNPJ, tax certificates, IPTU/charges debts, condominium regulations; documentary checklist before signing.
• Bylaws and corporate purpose: drafting in Portuguese, mention of legal form (Ltda/S.A.), explicit real estate purpose, headquarters verified by local authorities for absence of sectoral/environmental restrictions.

Governance and Operations

• Management powers: clear delegations to the local administrator; approval clauses for major operations at the SCI level.
• Accounting and taxation: local Brazilian bookkeeping, filing with authorities; synchronization with SCI accounting.
• Cross-border flows: registration of contributions/loans with the Central Bank of Brazil, foreign exchange compliance, and repatriation of dividends/interest.

Practical Implementation Steps

• Incorporation: choice of form (often Ltda), preparation of bylaws, publication/registration, obtaining CNPJ, proof of headquarters (title/lease), local licenses if necessary.
• Directors: appoint a resident individual (Brazilian or foreigner with permanent visa) as administrator; for S/A, at least two directors.
• Real estate registrations: escritura at the notary then registration at the Registro de Imóveis; obtain the updated certidão de matrícula free of encumbrances/mortgages.

Collaboration with Local Experts

• Brazilian real estate/corporate lawyer for bylaws, governance, leases, and audit of local risks.
• Notary and land registry to secure the escritura and title registration.
• Accountant/tax specialist for tax regime, transfer pricing, withholdings at source, CNPJ obligations.
• Licensed real estate broker (CRECI) for the transaction and document compliance.

Common Pitfalls to Avoid

• Buying in the name of the French SCI directly in Brazil without a local entity, exposing to registration, tax, and liability complications.
• Forgetting registration at the Registro de Imóveis: without registration, no enforceable property transfer.
• Absence of resident administrator: non-compliance and banking/administrative blockage.
• Incomplete bylaws: omission of clauses on intra-group financing, exits, quota transfers, which complicate management and exits.
• Insufficient due diligence: IPTU debts, charges, condominium defects, undetected easements.
• Non-compliance with zoning/licenses for the headquarters or building use.
• Underestimation of withholdings and tax obligations on dividends/interest and non-compliance with local accounting obligations.

Structuring Best Practices

• Standard scheme: SCI (France) → operational Brazilian holding (often Ltda) → holding of the building; shareholders’ agreement and intra-group agreements aligned with Brazilian laws.
• Governance clauses: enhanced quorum for transfers, financing, mortgages, distributions.
• Documentary compliance: bylaws in Portuguese, precise corporate purpose, justified headquarters, resident administrator appointed, updated registries.
• Transactional compliance control: CRECI validation, escrituras and tax certificates before any payment; systematic checklist.

Practical note: for large or multi-investor projects, consider an S/A for governance and fundraising; for most asset acquisitions, the Ltda remains the most efficient local structure.

The Tax Benefits of a SCI in Brazil

The legal forms equivalent to a “SCI” in Brazil are mainly the real estate limited liability company (Sociedade Limitada – “LTDA”) and, for simple asset holding, the condominium or real estate fund (FII – Fundo de Investimento Imobiliário) rather than a French-style SCI. For a foreign investor, applicable tax regimes focus on taxation of rental income, real estate capital gains, and deductibility of expenses, with specifics depending on the chosen structure.

Applicable Tax Regimes for a “SCI”-type Real Estate Company in Brazil

• Corporate Income Tax (IRPJ) + Social Contribution on Net Profit (CSLL): actual profit regime, with accounting and taxable base after deductions. Rental income is taxed as operating result; capital gains on disposal are integrated into the result. Necessary, usual, and justifiable expenses are deductible (management, maintenance, insurance, fees, interest, depreciation per Brazilian rules).
• Simplified regimes for small businesses (Simples Nacional): potentially accessible depending on activity, revenue, and classification of real estate leasing/administration; offers unified and reduced rates but with eligibility and sectoral restrictions.
• Real Estate Investment Funds (FII): collective vehicle with its own tax regime; possible exemptions on distributions for resident individuals meeting dispersion conditions, and specific taxation for non-residents; favorable taxation on gains and income at the fund/investor level per applicable rules.
• Indirect tax reform: gradual replacement of PIS/Cofins/IPI/ICMS/ISS by a dual VAT (CBS/IBS) and a selective tax (IS), with common rules and transition period; impact mainly on services and management (operating costs), not directly on IRPJ/CSLL of rents, but on recovery/charge of taxes on services.

Potential Tax Benefits for Foreign Investors

Rental Income:

• Under actual profit regime in a company (real estate LTDA), possibility to deduct necessary expenses: management and administration fees, maintenance and repairs, insurance, local property taxes, legal/accounting fees, interest on loans, and certain depreciation provisions per regulations, reducing the IRPJ/CSLL base.
• Simples Nacional: reduced effective rates and simplified calculation/collection if eligible; however, fine deduction of expenses is replaced by a presumed base via schedules.
• FII: the investor sometimes benefits from exemption on distributions (for resident individuals, under free float conditions and absence of position >10%); for foreign investors, taxation at specific rates on distributions and gains, often more competitive than IRPJ/CSLL at an operational company level.

Capital Gains on Resale:

• In a company taxed under IRPJ/CSLL, the capital gain is integrated into the result, allowing for loss compensation and consideration of depreciation; taxation follows corporate rates, which can be lower than some scales applicable to individuals.
• FII: gains on sale of shares taxed per investor category; taxation can be lighter than direct sale of a building via a company, depending on rates in force for non-residents.

Deductions/Credits:

With the CBS/IBS reform, recovery of VAT credits on services and supplies related to management/maintenance could improve depending on the chain of incidence, decreasing the net operating cost for operators subject to CBS/IBS.

Comparison with Other Real Estate Investment Forms in Brazil

Direct Holding by Non-Resident Individual:

• Rental income taxed in Brazil at flat rates for non-residents, with more limited deduction possibilities than via a company; specific reporting obligations and withholdings at source.
• Capital gains taxed per specific scales for non-residents; no access to planning via accounting depreciation as in a company.

Local Company (LTDA) versus FII:

• LTDA: better control of deductions and debt structuring; useful for individual assets, development operations, or concentrated holdings.
• FII: often preferential regime on distributed income and better liquidity if listed; however, regulatory constraints, fund management fees, and exemption conditions may limit the advantage for certain foreign profiles.

Simples Nacional (if eligible) versus Actual Profit Regime:

Simples: simplicity and potentially lower effective tax burden for modest rental income and light structure; but revenue caps and possible exclusion of certain incorporation/leasing activities.

Conditions, Restrictions, and Points of Attention

• Eligibility for Simples: revenue caps, nature of leasing/administration activity, shareholder composition; certain real estate activities may be excluded.
• Treatment of non-residents: withholdings at source and specific rates on dividends/FII distributions; requirements for local tax registration, fiscal representative, and foreign exchange and capital registry compliance.
• Depreciation and interest: strict deductibility rules; interest between related parties subject to transfer pricing and thin capitalization limits.
• Local taxes: IPTU (municipal property tax) and ITBI (transfer tax) not eliminated by CBS/IBS reform; acquisition/disposal costs to integrate into profitability calculation.
• Tax treaties: absence or presence of an applicable treaty can affect withholding at source and elimination of double taxation at the investor level.

Recent Legislative/Fiscal Evolutions Influencing Attractiveness in 2023-2025

• Indirect tax reform: adoption of a dual VAT model with CBS (federal) and IBS (States/municipalities) and creation of a selective tax (IS); multi-year transition, harmonization of rules, and gradual elimination of PIS/Cofins/IPI/ICMS/ISS; expected impact: simplification, better neutrality, possibility of upstream credits for management/maintenance services, which can improve the net yield of corporate structures.
• Debates on IR and corporate IS: reform project planning the introduction of a dividend tax (currently not taxed at the shareholder level in Brazil) compensated by a reduction in corporate tax; this point, discussed in 2023, would affect comparison between holding via company (dividend distribution) and via FII or direct holding. Final schedule and parameters to be monitored.

When is Each Regime Generally Most Interesting?

• Company under actual profit IRPJ/CSLL: leased assets with high charge intensity (capex/opex) and use of debt, allowing optimization via deductions and depreciation.
• Simples Nacional: small portfolios with simple operations and reasonable margin, if the activity is eligible.
• FII: strategy focused on regular distributions and liquidity, or investors seeking potentially lighter flow taxation regarding fund rules.

Structure	Rental Income	Capital Gains	Deductions/Expenses	Key Points/Restrictions
Company (LTDA)	Taxed via IRPJ/CSLL on net profit	Integrated into result, loss compensation possible	Broad deductibility (management, maintenance, interest, depreciation)	Accounting compliance; WHT non-residents on remittances; transfer pricing
Simples Nacional	Reduced unified rates if eligible	Simplified scales	Deductions replaced by presumed base	Revenue caps; sectoral exclusions
FII	Distributions with preferential regime, conditions	Gains on shares taxed per status	Expenses managed at fund level	CVM rules; exemption conditions; management fees

Important: exact rules (rates, bases, exemption and eligibility conditions for real estate activities under Simples, FII taxation for non-residents, depreciation) must be confirmed for the targeted period and according to the nature of income (residential vs commercial leasing) and holding structure.

Understanding the Brazilian Legal Framework for SCIs

Sociétés civiles immobilières do not exist as an autonomous legal form in Brazilian law; their functional equivalent relies on Brazilian corporate law vehicles (notably the Sociedade Limitada – Ltda. and the Sociedade Anônima – S.A.) used for real estate purposes, or, for condominiums, on the regime of condomínios governed by law.

In this framework, the “legal framework of SCIs in Brazil” is analyzed via: (i) general company laws; (ii) real estate and registration laws; (iii) taxation and accounting applicable to real estate holding companies; (iv) leasing and property transfer rules.

Essential Real Estate Legal Bases

• Brazilian Civil Code, Law No. 10.406/2002: property rights, real rights, contracts, condominium, promise of sale, usucapion, and the principle of effectiveness of land registry registration for constitution/transfer of real rights.
• Law No. 8.245/1991 (Lease Law – Lei do Inquilinato): governs urban leases, rights and obligations of landlords/tenants, lease guarantees, adjustments, termination, and eviction procedures.
• Law No. 4.591/1964 (Condominiums and incorporations): governs the condominium (condomínio edilício) and real estate development (sale off-plan).
• Law No. 6.766/1979: urban subdivisions, land division, and approval requirements.
• Public registries and transfer: Civil Code (art. 1.227–1.245) and Lei dos Registros Públicos; property is only transferred upon REGISTRATION at the competent Registro de Imóveis; registration is constitutive of the real right and ensures authenticity, security, and effectiveness.

Creation and Registration of a “SCI” via a Brazilian Company

Usual Forms:

• Sociedade Limitada (Ltda.): partnership/capital company, articles of association registered at the State Junta Comercial; very common for holding real estate assets.
• Sociedade Anônima (S.A.): joint-stock company, heavier governance; useful for large projects.

Key Steps:

• Drafting of bylaws/articles of association defining the real estate purpose (acquisition, leasing, development, management).
• Registration at the Junta Comercial (incorporation of the legal entity).
• Obtaining the CNPJ (tax number) from the federal tax authority.
• Municipal licenses where applicable (e.g., commercial furnished leasing activity).
• Acquisition/transfer of buildings: notarial deed (escritura pública, except exceptions), payment of transfer taxes (ITBI), and registration at the competent Registro de Imóveis; only registration transfers ownership.
• Specifics for foreigners: need for a CPF for individuals and a fiscal representative; sectoral/zoning limits may apply (e.g., border zones, rural) and vary locally.

Typical Tax Obligations of Real Estate Companies

At Acquisition:

• ITBI (municipal inter vivos transfer tax) due upon registration of the transfer; the rate is municipal and conditions registration.

In Holding:

• IPTU (urban property tax, municipal) or ITR (rural) depending on location; liable: registered owner or possessor.
• Condominium taxes/charges (condomínio) for units in condominiums governed by Law 4.591/1964.

Rental Income:

• Taxation at the company level per chosen tax regime (Simples Nacional not available for most passive holding activities; alternatives: Presumed Profit vs Actual Profit).
• Usual federal levies on income: IRPJ, CSLL, PIS/COFINS (rates and base per regime).

Capital Gains on Disposal:

• Capital gains tax at the company level (IRPJ/CSLL) calculated per regime; ITBI not due in case of share sale (unless reclassified as property transfer), but attention to municipal control.
• Withholding at source: certain distributions to non-residents may suffer IRRF; tax treaties to verify.

Accounting and Compliance Obligations

• Bookkeeping per Brazilian standards (BR GAAP converged to IFRS for S.A.; Ltda. may keep simplified accounting if eligible, but regular bookkeeping is essential for profit allocation and capital proof).
• Periodic tax filings (federal, state if applicable, municipal).
• Meetings/corporate acts: approval of annual accounts; filing of major acts at the Junta Comercial.

Rights and Duties of Partners/Shareholders

Rights:

• Participation in results, voting per shares, information, preference in capital increases, right of withdrawal in certain cases (per Civil Code/S.A.).

Duties:

• Capital contributions, respect for affectio societatis and articles of association clauses, non-competition/confidentiality if stipulated.

Liability:

• In Ltda., limited to contributions, subject to piercing the corporate veil in case of abuse; in S.A., liability limited to subscription.

Governance: Usual Clauses for Real Estate Holding Companies

• Qualified quorum for acquisition/disposal of buildings.
• Policy for distribution of rents/dividends.
• Agreement/temporary inalienability pacts for shares.
• Mechanisms for independent asset valuation.

Specifics of Real Estate Law Impacting Management via Company

Urban Leases (Law 8.245/1991):

• Admitted guarantees: surety (fiador), deposit, guarantee insurance.
• Adjustment by index (e.g., IPCA/IGP-M) if stipulated; judicial revision possible at end of three-year period.
• Eviction procedures regulated; enhanced protections for residential tenants, with exceptions for motivated termination.

Condominium (Law 4.591/1964):

• Condominium conventions, meetings, charges, reserve funds; role of the syndic; sanctions in case of arrears.

Property Transfer and Land Publicity:

• Need for notarial deed and registration; property is only transferred upon registration; chain of titles and encumbrances (mortgages, usufructs) verified at the cartório de Registro de Imóveis.

Usucapion/Social Housing:

• Mechanisms of special urban usucapion with administrative procedures since 2009 for good faith possession on small areas, impacting land security and due diligence.

Civil Procedure and Registries:

• The New CPC (Law 13.105/2015) strengthened articulation with notarial and registry activity, facilitating certain administrative steps in substitution of judicial route, with effect on land regularization.

Case Studies and Practical Examples

Acquisition of a Rental Building by a Ltda.:

• The company signs a escritura pública at the notary, pays the municipal ITBI, and files the deed at the Registro de Imóveis; ownership is only acquired upon registration.
• Rents received are accounted for; the company opts for Lucro Presumido to simplify taxation of rental income; distribution of results to partners per articles of association.
• In case of arrears from a residential tenant, the company uses the provided lease guarantee and files an eviction action per Law 8.245/1991, respecting deadlines and notifications.

Sale of Condominium Units via Development:

• A real estate development S.A. registers the development memorial and condominium description per Law 4.591/1964, sells “off-plan”, and transfers each unit by individual registration at the Registro de Imóveis; condominium charges become payable by the new owner from registration.

Regularization of Prior Urban Occupation before Purchase:

• During due diligence, the company discovers an occupant with possession title; considering rules of special urban usucapion and the instituted administrative procedure, the company negotiates a compensated evacuation or integrates the risk into the price.

Foreign Investor:

• Non-resident partners obtain a CPF and appoint a fiscal representative; the Ltda. receives a CNPJ; the building is acquired and registered; non-compliance with formalities delays registration and thus property transfer.

Contractual Best Practices for a Real Estate Holding Company

• Indexation and rent adjustment clauses compliant with Law 8.245/1991.
• Prior verification at the cartório: chain of titles, mortgages, easements, condominium charges, disputes.
• Adapted governance: investment committee, independent expertises for transactions with related parties.
• Tax monitoring: ITBI calculation upfront, optimization of IRPJ/CSLL regime, control of IPTU and charges.
• Lease risk management: choice of guarantees, rent insurance, compliant eviction procedures.

Point of attention: States and municipalities add local requirements (ITBI rates, procedures at the Registro de Imóveis, urban norms); local verification is indispensable before any investment.

Domain	Key Rule	Impact for a Real Estate Company
Property Transfer	Constitutive registration at Registro de Imóveis	Closing is only effective upon registration; strict management of deadlines and taxes
Urban Leases	Law 8.245/1991	Standardized contracts, guarantees, revisions; regulated eviction procedures
Condominium	Law 4.591/1964	Mandatory charges, syndic governance, respect of regulations
Company Law	Civil Code/Ltda. and S.A. Law	Limited liability; bylaws must provide for real estate purpose
Transactional Taxation	Municipal ITBI	Acquisition cost; depends on value and municipality
Recurrent Taxation	IPTU/ITR	Operating budget; possible non-exigibility for limited contested periods
Land Regularization	Special Urban Usucapion	Risk on possession; enhanced due diligence
Procedure/Registries	New CPC 2015	Increased administrative routes for certain registrations

Avoiding Pitfalls When Investing in Real Estate with a SCI in Brazil

The main pitfalls to avoid relate to the unsuitable transplantation of the French SCI model into a Brazilian environment governed by fundamentally different law and taxation, as well as the macroeconomic risks specific to Brazil.

• Do not presume that the SCI is recognized as such in Brazil: the SCI is a French civil law company; in Brazil, real estate vehicles and their tax/contractual regimes are distinct, and the absence of strict equivalence can create cross-border fiscal and legal frictions.
• Underestimate Brazilian tax complexity (multiplicity of federal/state/municipal taxation levels, heavy formalities, atypical transfer pricing controls), source of costs, delays, and audit risks.
• Ignore applicable tax treaties and the method for eliminating double taxation for Franco-Brazilian flows (dividends, interest, director remuneration), with specific withholdings at source and tax credits.
• Neglect exchange rate risks related to the Brazilian real (BRL) and their effects on asset value, rent flows, debt, and consolidation of accounts in strong currency.
• Omit to map restrictions on foreign ownership (border, rural, coastal zones, or related to national security), which often require specific structures or authorizations in Brazil.
• Import non-transferable SCI optimization schemes (e.g., shareholder current account, fiscal transparency) potentially leading to different qualification and reassessments in France and/or Brazil.

Specific Legal and Tax Points in Brazil (and Differences with International and French Law)

Property Rights and Land Publicity

• Brazil relies on local real estate registries and thorough land due diligence procedures; enforceability and chain of titles require heavier notarial/registry verifications than in France, without presuming the same legal security inter-jurisdictions.
• Contracts must respect Brazilian legislation applicable to the property located in Brazil (lex rei sitae), even if the holding structure is foreign, limiting the practical scope of purely international setups.

Local vs. International Taxation

• Multiplicity of taxes and contributions (federal/state/municipal) and Brazil-specific transfer pricing rules, not fully aligned with the OECD framework, complicating intra-group flows and deductibility.
• Income related to director/administrator functions may be taxed at source in the State of residence of the company, with correlative tax credit in the other State per the France-Brazil treaty.
• Tax choices of the SCI in France (IR “transparency” or IS) have implications on withholdings and tax credits, as well as on cross-border accounting and reporting.

Economic Risks to Highlight

Volatility of the Brazilian currency (BRL) impacting:

• Asset valuation and flows (rents, dividends, interest), debt service in strong currency, and asset value test.
• Need for hedging policies, locally compatible indexation clauses, and currency alignment of rents/debts.

Cycles of the Brazilian real estate market influenced by domestic interest rates, credit, growth, and local regulation; local market granularity (city/neighborhood) increases execution risk.

Indispensable Due Diligence

• Land and urbanistic verifications: chain of titles, encumbrances, disputes, compliance, permits, land and municipal taxation.
• Multi-level tax review: taxes on income/capital gains, operational taxes, transfer pricing, withholdings at source, treaty tax credits.
• Legal structuring: compliance of bylaws, shareholders’ agreements, representation powers, local substance where applicable.
• Assessment of exchange and liquidity risks: stress scenarios, hedging policies, treasury governance.
• Consultation of local experts (lawyers, tax specialists, notaries/registrars, accountants), and coordination with advisors in France for bilateral consistency.

Possible Restrictions on Foreign Ownership and Legal Precautions

• Acquisition limits for non-residents in certain zones (rural, border, sensitive), and required authorizations/structures in Brazil.
• Compliance requirements for foreign entities: registration, legal representatives, local bookkeeping, and reporting.
• Provide robust contractual clauses: liability guarantees, suspensive conditions, title resolutions, arbitration/jurisdiction, lawful indexations, force majeure.

Practical Tips for Tax Optimization and Management of an International SCI

Choice of SCI Tax Regime in France

• At IR: fiscal transparency, but necessary coordination with Brazilian taxation of flows and withholdings at source; attention to implications for non-resident partners.
• At IS: reinforced accounting obligations, but better control of effective rate and amortization; require accrual accounting, annual meeting, filing of accounts, and, depending on thresholds, statutory audit.

Planning of Flows and the France-Brazil Treaty

• Map withholdings (dividends/interest/services) and tax credits, including for director remuneration; optimize the nature of flows and location of substantial functions.
• Avoid setups without economic substance; align substance (headquarters, effective management, personnel) with claimed tax residence.

Management of Exchange and Debt

• Currency alignment of income and debt; use authorized hedging instruments; define covenants compatible with BRL volatility.

Governance and Compliance

• Implement transfer pricing policies compliant with Brazilian rules; robust and defensible documentation in audit.
• Bilateral compliance calendar (filings, withholdings, account filings) and data room of proofs for treaty tax credits.

Exit and Capital Gains

• Anticipate treatment of capital gains in France for non-resident partners and implications of debts/advances in shareholder current account on valuation and taxation at exit.

Summary Table of Vigilance Areas

Domain	Key Risk	Preventive Measure
Recognition of SCI	Requalification, conflicts of laws	Appropriate local vehicle, Brazilian legal opinions
Multi-level Taxation	Double taxation, reassessments	Tax mapping, treaty application, tax credits
Transfer Pricing	Brazil-specific methods	Local documentation, economic alignment
Exchange (BRL)	Erosion of yields	Hedging, currency alignment of rents/debt
Foreign Ownership	Restrictions/authorization	Regulatory due diligence, compliant structuring
SCI Governance (IS/IR)	Non-compliance, penalties	Regime choice, respect of accounting obligations
Cross-border Flows	Withholdings at source	Flow structuring, proofs for tax credits

Operational Checklist

• Complete land, tax, regulatory due diligence (Brazil and France).
• Validation of vehicle strategy: SCI alone vs. dedicated Brazilian entity.
• Financial modeling in scenarios (rates, exchange, rents, exit).
• Documented hedging and treasury policy.
• Contracts with protection clauses and adapted arbitration.
• Governance, accounting, and bilateral compliance calendar.
• Transfer pricing and treaty documentation.
• Periodic reviews with local and French advisors.

Key message: real estate investment in Brazil via a SCI requires structural adaptation, mastery of tax treaties and Brazilian taxation, active management of exchange risk, and equipped bilateral governance, with support from local experts.