Brazil to Issue Guidance on Advance Tax Agreements by Year-End

The Brazilian government intends to release guidance on unilateral advance pricing agreements before the end of the year, a tax official said Wednesday.

The guidance will be released with the goal of getting Brazil’s APA program working in the early part of 2026, Daniel Prates, coordinator of international taxation at the Federal Revenue Service, said at the International Fiscal Association’s tax Congress in Lisbon.

APAs allow a company to receive a binding ruling from a tax authority about its transfer pricing positions—its valuation of intercompany transactions—for a certain number of years. Companies that can afford the costly process like ...