Brazil’s Federal Revenue Service has ruled that isolated stablecoin transactions held abroad are not subject to IOF-Cambio, while separate foreign exchange operations conducted by virtual asset service providers remain taxable.
Brazil’s tax authority, the Federal Revenue Service (RFB) has clarified that the isolated acquisition, sale, negotiation, or exchange of stablecoins held abroad does not constitute a foreign exchange operation subject to the Tax on Financial Operations (IOF-Cambio). The interpretation was established in Ruling No. 218/2026, which was published in the Official Gazette on 6 November 2026.
Ruling No. 218/2026 examines cross-border stablecoin transactions facilitated by a Brazilian financial institution through a foreign virtual asset service provider (VASP).
The legal definition of the taxable event of IOF-Cambio
Under Article 63(II) of Brazil’s National Tax Code and Article 11 of Decree No. 6,306/2007, IOF-Cambio applies to foreign exchange operations involving the delivery of national or foreign currency, or documents representing such currency. Article 38 of BCB Resolution No. 277/2022 further requires the reciprocal delivery of both currencies to complete an exchange transaction. Therefore, the acquisition or disposal of digital assets alone does not meet the legal requirements for triggering the tax.
Stablecoin transactions in isolation
The RFB clarified that the isolated acquisition, sale, or exchange of stablecoins abroad does not constitute a foreign exchange operation. In these transactions, clients exchange Brazilian Reais (BRL) for virtual assets held abroad or sell those assets in return for foreign currency offshore or BRL in Brazil. As no direct exchange of national and foreign currencies takes place, these transactions are not subject to IOF-Cambio.
Pure movement in non-resident accounts in BRL (CNR)
Under Article 67 of BCB Resolution No. 277/2022, authorised institutions may maintain BRL accounts for non-residents. The RFB clarified that the movement of funds within these accounts does not, by itself, constitute a foreign exchange operation. Although transferring BRL from a Brazilian resident’s account to a foreign VASP’s non-resident account qualifies as an international transfer of resources (TIR), it does not involve the delivery of foreign currency in Brazil. The subsequent transfer or availability of virtual assets and foreign balances takes place offshore.
Intermediary VASP operations and tax liability
The ruling distinguishes clients’ stablecoin transactions from independent foreign exchange operations conducted by VASPs. Where a VASP acts without a mandate to execute foreign exchange contracts on behalf of its clients, its transactions remain separate from the clients’ digital asset trades. However, if the VASP independently enters into a foreign exchange contract to transfer funds abroad or bring foreign balances into Brazil, that operation is subject to IOF-Câmbio. The VASP bears the resulting tax liability in its own name, which does not extend to the client’s underlying stablecoin transaction.
