Changes to Brazilian Transfer Pricing Rules

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Provisional Measure (MP) 1152, published on December 29, 2022, substantially amended the Brazilian transfer pricing rules currently in force fo transactions caried out between related parties, with the purpose of aligning them with OECD Guidelines.

The MP comes into effect on January 1, 2024, but taxpayeers may choose to apply it as from January 1, 2023. The MP is still pending regulation by the Brazilian Federal Revenue Service…

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