Brazil introduced Provisional Measure No. 1152 on December 29, 2022, updating its transfer pricing rules to align more closely with international standards, especially as the country evaluates its integration with the OECD.
The new rules, which will become mandatory starting in 2024, address controlled transactions, comparability analysis, and the selection of the most appropriate method. They also regulate transactions involving intangibles, intra-group services, cost-sharing contracts, and transactions concerning debt and guarantees.
Taxpayers have the option to adopt the new regulation as early as 2023. We have prepared this e-book with insights from our partners on the main impacts of applying the new rules, the transactions covered within their scope, and the contentious issues. Take a look!