For decades, Brazilian wealth structured abroad through improvisation: offshore centres, layered nominees, structures that worked until they suddenly did not. Two things have changed. Brazilian tax reform has redrawn how offshore holdings are treated, and Switzerland and Brazil now have a double taxation agreement in force, one of the newest in the Swiss network.
The professional consequence is clear: the improvised era is over, and the corridor now rewards structures built properly in a jurisdiction of standing. A Swiss holding company gives Brazilian ownership exactly that, with banking and substance to match.
The Switzerland Brazil double taxation agreement, in force since 2022, put this corridor on a footing it never had before. Structured flows between the two countries now rest on treaty ground.
Brazilian reforms on offshore entities changed the calculus for the old routes. A Swiss holding company with real substance is the destination structure, not another waypoint.
From agribusiness to technology, Brazilian groups win when they face Europe as a European counterparty. A Swiss entity provides the contracting standing and the banking relationships to operate at full value.
Seraama is a Zug based boutique founded by a UK qualified lawyer with twenty three years of international corporate experience. We form the Swiss company, provide the resident director and registered office that give it real substance, prepare the banking file and make the introduction. One firm, one standard, personally accountable for what we build.
We take a limited number of clients, principally from the Gulf, Asia, Africa and Latin America, and most arrive through professional referral. Fees are quoted in writing after a short consultation; we do not publish price lists, deliberately.
Before 2022 the corridor operated without treaty protection, which pushed Brazilian wealth toward third jurisdictions. With the agreement in force, a direct Brazilian Swiss architecture became viable: flows between the two countries now have negotiated withholding rates and dispute mechanisms. Structures built for the old world deserve re-examination.
Brazilian reforms brought offshore holding structures under closer taxation and reporting. The Brazilian side of that analysis belongs with your Brazilian advisers; our role is to ensure the Swiss side is a substantial, defensible entity rather than the kind of paper structure the reforms target. We coordinate both sides on every mandate.
A Swiss holding level above Brazilian operating companies is a recognised architecture, now with treaty support behind it. Whether it is right for you depends on ownership, succession intentions and exit plans. That is a design conversation we hold before any formation.
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