New Brazil Tax Rules Poised to Capture Commodity Export Boom

July 4, 2025, 9:07 AM UTC

The Brazilian government’s adoption of the arm’s-length standard for its transfer pricing regime this year came just in time to capitalize on a commodities boom in the country.

The arm’s-length standard move was mostly to align Brazil’s system with that of the Organization for Economic Cooperation and Development. But it’s also expected to raise revenue, especially from the agriculture, energy, and mining sectors.

“Commodities seem to be the biggest target here for sure,” said Fernando Colucci, partner at Machado Meyer in Sao Paulo. “Especially when we are thinking about exports of commodities, the feeling ...

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