Brazil Taxpayers Clamor for Promised Transfer Pricing Guidance

Brazil’s shake-up of its transfer pricing rules last year has yet to get the flood of guidance that taxpayers say is needed to comply with the new system.

Since the rules took effect in January 2024, the government has issued an instruction for commodity trading operations, but taxpayers are still waiting for guidance on such crucial topics as advance pricing agreements, or APAs, intercompany services, cost sharing, and financial transactions.

“Most of this guidance should have been released really before Dec. 31, and it wasn’t,” said Nina Baumbach, senior manager at RSM US LLP. “And we are not really ...