Brazil Urged to Widen Scope, Accessibility of Advance Tax Pacts

Tax pros say Brazil’s new system of allowing companies to gain advance agreements on their transfer pricing methods provides much-needed tax certainty but should be more accessible and wider in scope.

There are restrictions to taking advantage of such agreements because of a requirement that companies take part in a pilot tax compliance program with the tax authority to qualify, practitioners said.

For the advance pricing agreement program to be most effective, practitioners said Brazil’s tax authority should strengthen confidentiality in the negotiations, remove limits on companies that can apply for them, and institute agreements that apply across other jurisdictions. ...