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Brazil Consulting on New Transfer Pricing Tax Regulations

IBX-Jakarta. Quoting from, Brazil’s Special Secretariat of the Federal Revenue is consulting stakeholders on a draft Normative Instruction that would regulate the country’s new transfer pricing regime.

Law No. 14596, introducing a new transfer pricing regime in Brazil, was gazetted on June 14, 2023. The new law expressly incorporates the arm’s length principle into the Brazilian legal system, and applies compulsorily from 2024.

The Normative Instruction would cover several aspects of the new transfer pricing law such as the definition of related parties, interpretive role of the OECD Transfer Pricing Guidelines, comparability analysis, selection of transfer pricing methods, among others.

It will also deal with administrative issues related to transfer pricing, in particular transfer pricing documentation, and simplification measures for intra-group services.