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LC 227 and Offshore: the law that changed the inheritance landscape in Brazil

Understand the impacts of LC 227 on succession planning, the advantages of a legal offshore structure, the use of asset valuation, and how investors and business families are reducing risks and taxe

The discussion surrounding wealth succession in Brazil has definitively entered a new stage. By reformulating the logic used to assess assets for inheritance and donation purposes, LC 227 did more than change tax rules — it repositioned the very concept of value. What was once treated as a static, accounting-driven and reactive matter now requires economic insight, strategic vision and a level of asset organization aligned with international standards.

The core of this shift lies in the convergence between succession law and real market practice. The law now recognizes that wealth is not merely the sum of isolated assets, but the result of structures, financial decisions, leverage, reinvestment and governance. In practice, this means that valuation is no longer purely formal and begins to reflect the true economic value of the c

This new environment directly affects business families, investors and executives who accumulate wealth through companies, equity holdings, financial assets and international structures. Succession ceases to be a one-time event and becomes a continuous process of wealth management.

Within this framework, offshore structures move away from a marginal or defensive role and become a central planning instrument. Offshore is no longer just about internationalization or isolated tax efficiency. It now functions as a tool for asset organization, economic valuation and long-term protection. When properly structured, integrated and disclosed, offshore vehicles allow the centralization of assets, the organization of global investments, the separation of operational risk from wealth, and the construction of a succession logic consistent with the new legal framework.

LC 227 reinforces this possibility by allowing valuations that consider leverage, reinvestment and capital structure. This opens the door for holdings — including international ones — to operate with reduced accounting net worth without any loss of real economic value. The practical outcome is a succession process based on equity interests valued by market criteria, rather than artificially inflated figures.

At the same time, the law has brought significant consequences for those who failed to prepare. The absence of structure, governance and planning now results in clear losses. Disorganized assets, properties held in individuals’ names, companies without capital strategy, or improvised international structures tend to face higher taxation, succession disputes, loss of efficiency and, in many cases, operational and fiscal restrictions.

The cost of poor planning goes beyond taxes. It lies in the loss of control, judicialization of succession, dilution of wealth and difficulty in business continuity. The new legislation has made these risks more visible — and more expensive.

On the other hand, for those who operate in a structured manner, the advantages are evident. The combination of a holding structure, economic valuation and offshore planning provides greater predictability, reduced tax exposure, legal protection, organized succession and preservation of legacy. From a financial perspective, the impact may represent the preservation of a significant portion of wealth accumulated over decades.

This model requires discipline. It requires governance, reporting, continuous legal and financial oversight. It requires treating wealth as a strategic asset rather than a collection of isolated properties. But it is precisely this mindset that distinguishes those who merely accumulate from those who preserve and perpetuate.

LC 227 did not create loopholes or shortcuts. It simply acknowledged a reality long applied by the market: value is built, not booked. Offshore structures, in this context, are not an exception. They are the logical consequence of modern, global and legally aligned wealth planning.

In the new regulatory environment, understanding the law, structuring assets properly and adopting market practices is no longer a competitive advantage. It has become a basic condition for those who wish to protect wealth, ensure efficient succession and maintain economic relevance over time.

Those who understand this shift do not react to the law. They anticipate it.

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