Brazil Releases Consultation on New Transfer Pricing Law

Brazil released draft guidance Monday explaining how its new transfer pricing law will operate.

Last month, Brazil’s president signed a sweeping transfer pricing overhaul into law. After years as an outlier on its rules for valuing intercompany transactions, Brazil has now adopted the arm’s length standard, aligning it with global norms.

• The Receita Federal, the tax authority, released the guidance or “normative instruction” as a consultation, open for comments until July 25.
• The rules become mandatory in 2024, but companies may choose to apply them in 2023.