Brazil Tax Official Details New Advance Tax Agreement Procedure

A Brazil revenue authority official Tuesday clarified how the office will conduct advance negotiations with companies to help them determine their transfer pricing methodology.

The tax office will discuss the method to determine profit margins when negotiating unilateral advance pricing agreements—not decide what those profit margins should be, Claudia Pimentel, undersecretary for taxation and litigation at Brazil’s Federal Revenue Service, said during a panel hosted by the International Fiscal Association.

Brazil opened a consultation in August seeking feedback on proposed regulations enforcing a 2023 law that introduced advance pricing agreements, or APAs, and use of the arm’s-length principle to ...