Cut Admission Rules for Advance Tax Pacts, US Group Asks Brazil

Brazil should scrap its proposed limits on who can apply to a program meant to reduce uncertainty in a firm’s transfer pricing, a major US business group wrote.

The proposed advanced pricing arrangement program shouldn’t restrict access only to companies that have completed a six-month pilot compliance program, and Brazil’s tax authority shouldn’t set limits on how many applications to receive annually, the American Chamber of Commerce said a public consultation submission.

Brazil is introducing advance pricing arrangements, or APAs, as part of a new transfer pricing law passed in June 2023. The ...