Value · Money and tax · lesson 7.1 open

PJ and Simples Nacional

The most common structure for professionals providing services abroad, Fator R, and questions for your accountant.

Promise: you understand the structure's setup and approach your accountant with questions, not vague doubts.

Disclaimer. This lesson describes general mechanisms, as published by accounting firms on 05/10/2026. It is not tax advice. Legislation changes; your specific case depends on municipality, business activity, and revenue. Confirm with an accountant before deciding.

Why PJ

International B2B contracts are signed with a company. To receive payments as a legal entity, you need a PJ (a Brazilian company registered by an individual contractor). The most common legal forms are the sociedade limitada unipessoal (single-member limited liability company) or an ME/EPP (microenterprise or small business classification). MEI (Brazil's simplified sole-proprietor regime) is generally not an option for high-value data consulting due to revenue limits and restricted business activity lists; confirm this with your accountant.

Business activity (CNAE)

The registered business activity determines your tax categorization. Frequently cited examples for your profile: custom software development (6201-5/01), information technology consulting (6204-0/00), and, for those working with data processing, 6311-9/00 (data processing, application service providers, and hosting services). Ask your accountant which CNAE (National Classification of Economic Activities) code reflects your service and how it affects the annex.

Simples Nacional, Annex III and V, Fator R

According to the consulted sources:

IT/development activities can start in Annex V (initial tax rate of 15.5%) and migrate to Annex III (initial tax rate of 6%) when Fator R (a ratio determining tax brackets under Simples Nacional, a simplified Brazilian tax regime for small businesses) is equal to or greater than 28%.
Fator R = payroll expenses over the last 12 months (includes pró-labore, the officer's compensation) ÷ gross revenue over the last 12 months.
Practical consequence: paying sufficient pró-labore can reduce the overall tax rate, but pró-labore is subject to INSS (Brazilian social security contribution) and personal income tax. The balance is a calculation for your accountant.

Revenue limits (2026, according to sources): up to R$ 4.8 million in the domestic market and an additional limit for export revenues (R$ 4.8 million, according to sources; LC 123/2006). Confirm this.

What exporting changes

When the invoice is correctly issued as an export of services, sources indicate that ISS does not apply and PIS/COFINS are excluded from the tax base. IRPJ/CSLL remain within the DAS (the unified Simples Nacional tax payment slip).

How the pieces fit together (an illustrative scenario, not a final rate)

Revenue of US$ 5,000 at an exchange rate of R$ 5,00 = R$ 25.000/month.

Fator R. To reach 28% of revenue, payroll (including pró-labore) would need to be around R$ 7.000/month at this revenue level. A pró-labore of R$ 3.000, for example, would result in a Fator R of 12% and keep the activity in Annex V.
Cost of pró-labore. It incurs partner INSS (the usual rate for an individual contributor is 11%, up to the ceiling; confirm) and personal income tax. A higher pró-labore reduces DAS, but increases these costs.
DAS on exports. On exported services, sources indicate that ISS and PIS/COFINS are excluded from the tax base, which reduces the effective rate compared to the standard table. The exact figure depends on your revenue bracket and annex breakdown: this is a calculation for your accountant.

The point of the example is the trade-off (pró-labore ↔ Fator R ↔ personal INSS/income tax), not a percentage. If someone promises you a single flat rate ("just 6%", "just 7%"), ask for the complete calculation.

Your number depends on the exchange rate, pró-labore, business activity, and municipality.

Tax reform in transition

Consumption tax reform (CBS and IBS, with a transition projected into the early 2030s) will replace taxes such as PIS/COFINS and ISS over the coming years. The tax treatment of exported services tends to be preserved, but transition rules and the impact on Simples Nacional must be confirmed with your accountant at the time you read this.

Questions for your accountant

Which regime and which annex apply to my business activity?
What pró-labore optimizes Fator R without hurting my personal cash flow?
How does my export revenue factor into the Simples Nacional limits?
What is my real effective tax rate (DAS + INSS + personal income tax) on every US$ 1,000 received?
How does profit distribution work and how is it taxed?

Do this now

Write down these five questions, add your own, and schedule a conversation with at least two accountants. Compare the answers.

Checklist

Do I have the questions written down?
Do I know what Fator R is and why it matters?

Sources (consulted on 05/10/2026): articles from Agilize, Contabilizei, Remessa Online, Colinear, TechFX, and Account Tech on service exports and Simples Nacional. Verify in LC 123/2006, CGSN Resolution 140/2018, and LC 116/2003.

Checked on 05/10/2026. Educational content; tax and legal: confirm with a professional.