Importing Goods into Brazil: RADAR, Import Taxes and the Tax Reform

Many foreign groups enter Brazil by selling products they make elsewhere: a Brazilian subsidiary imports from the group and distributes locally. Before the first container arrives, the subsidiary needs a customs registration with a limit that matches its volumes, a decision on whether to import directly or through a trading company, and a realistic estimate of the import taxes, which in Brazil are layered and partly calculated on top of each other. The consumption tax reform will change most of these taxes from 2027. This guide covers what a foreign-owned importer needs to know.

Step one: the Siscomex registration (RADAR)

To import, a Brazilian company must be registered to operate in Siscomex, the foreign trade system. The registration, still widely known by its old name RADAR, is governed by Federal Revenue Normative Instruction 1,984/2020 and requested online through the Habilita system in the Single Foreign Trade Portal. It comes in three main forms:

The financial capacity is estimated from federal taxes the company has actually paid (corporate income tax, CSLL, PIS and Cofins, or social security contributions) in the current year and the four previous years. That is the catch for a new subsidiary of a foreign group: with no tax history, it will usually start with a low limit. A review of the estimate can be requested, and planning this early avoids the first shipments being stuck. Exports have no limit. The registration lapses after 12 months without operations.

Importing directly or through a trading company

A subsidiary that cannot yet import in its own name, or prefers not to, can use a trading company under one of two models regulated by the Federal Revenue:

• Import on behalf of the buyer (conta e ordem): the subsidiary is the real buyer and pays the supplier with its own funds; the trading company only carries out the customs clearance. The subsidiary’s tax ID appears in the declaration.
• Import to order (encomenda): the trading company buys with its own funds and resells to a predetermined buyer, the subsidiary.

Both shift operational work to the trading company, but the subsidiary still bears the tax cost and, in the first model, shares responsibility for the operation.

The import taxes today

Import taxes are calculated on the customs value, which under the GATT Valuation Agreement and the Customs Regulation (Decree 6,759/2009) generally includes the price of the goods, freight to the port or airport of arrival, handling and insurance: in practice, a CIF basis.

Because ICMS is calculated “inside” its own base and on top of the other taxes, the total landed cost can be well above the sum of the nominal rates. Companies under the non-cumulative regime can generally take PIS and Cofins credits on imports, and ICMS is creditable for companies that resell or manufacture, subject to state rules. Modeling the landed cost per product, with the correct NCM, should come before pricing decisions.

Ex-tarifário and special regimes

Capital goods and IT and telecom goods without equivalent production in Brazil can benefit from a temporary reduction of import duty under the ex-tarifário regime, granted by the foreign trade chamber’s executive committee (Gecex). Exporters and manufacturers can also use special customs regimes such as drawback, which suspends or exempts taxes on inputs used in exported products, and RECOF, a customs-controlled industrial warehouse regime.

A new import declaration

Brazil is replacing the old import declaration (DI) and import licenses with the single import declaration (DUIMP) in the Single Foreign Trade Portal, in phases by type of operation. The government publishes and periodically updates the schedule; importers and their customs brokers should check which operations already require DUIMP.

What changes with the tax reform

The consumption tax reform replaces most of the taxes above:

• From 2027: PIS-Import and Cofins-Import are abolished and replaced by the federal CBS on imports, charged at the same rate as domestic supplies, with the importer as the taxpayer. IPI is reduced to zero, except for products with incentivized manufacturing in the Manaus Free Trade Zone, and a Selective Tax applies to certain goods.
• 2029 to 2032: ICMS is reduced gradually as the state and municipal IBS increases.
• 2033: ICMS is extinct; imports bear CBS and IBS.

The CBS and IBS base on imports is the customs value plus import duty, the Selective Tax, the Siscomex fee, AFRMM and similar charges, but excludes IPI, ICMS and ISS, so the “tax on tax” effect is reduced. Import duty is not part of the reform and remains. For importers that resell or manufacture under the regular regime, CBS and IBS on imports are creditable. See Brazil’s tax reform explained for foreign headquarters.

A checklist before the first shipment

1. Confirm the tariff codes (NCM) of the products and any licenses or regulatory approvals they need.
2. Request the Siscomex registration, and a capacity review if the expected volume exceeds the initial limit.
3. Decide between importing directly or through a trading company.
4. Model the landed cost and the credits for each product under the current rules and from 2027.
5. Agree the transfer price for goods bought from the group, which must follow the arm’s length principle (see our transfer pricing guide).
6. Choose a customs broker and a freight forwarder, and set up the accounting for imports and foreign exchange.

How Solidy can help

Solidy already serves subsidiaries of multinational companies in Brazil, including logistics companies. Our tax and accounting teams model landed costs and credits, help plan the Siscomex registration and its limit, and keep the import accounting, foreign exchange and tax records in order. Read about accounting and tax for freight forwarders in Brazil or talk to our specialists.