New transfer pricing rules in Brazil: opportunities & risks

On 15 June 2023, the provisional measure n. 1152/22 – published on 29 December 2022 – was converted into law with the publishing of Federal Law n. 14.596/23 (the “Law”). With the Law, Brazil’s transfer pricing (“TP”) rules are aligned with the at arm’s length standard as reflected in the OECD TP Guidelines (“TPG”). Brazilian taxpayers need to comply with the Law for financial years starting on or after 1 January 2024 (FY2024). However, they also have the option to ‘early adopt’ to the Law with respect to the prior financial year.

In our newsflash we have highlighted some key aspects, risks, opportunities & next steps with regard to the Law.