Transfer Pricing in Brazil: Practical Aspects in the Adaptation of the Arm’s Length Standard

Brazilian taxpayers need to comply with new OECD-based transfer pricing rules as of financial years starting on or after 1 January 2024. They are also allowed to apply the new rules for financial years starting on or after 1 January 2023, if they choose for “early adoption” later this calendar year.

This IBFD article by Eli van Exel, Taco Wiertsema (Atlas Tax Lawyers) and Francisco Lisboa Moreira (Alma Law) outlines the practical impact of the new rules for Brazilian taxpayers, based on its underlying concepts and a case study including intra-group transactions that Brazilian taxpayers are commonly engaged in. In addition, the authors aim to illustrate some key considerations, opportunities, and risks of the upcoming decision whether to adopt early.

Please find the article here.

Questions? Please contact Eli van Exel or Taco Wiertsema.