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Brazilian Federal Revenue Service and the Inter-American Development Bank hold seminar as part of process to present new Brazilian transfer pricing system

|Tax Alerts, National/Federal Taxation, Transfer Pricing|Brazil
Brazil

  • The commodity concept under the proposed transfer pricing system would follow market practice and the definition of intangible would align with the OECD Transfer Pricing Guidelines.

  • The new system would require taxpayers to present the local and master files, together with the already required country-by-country report.

  • Questions still remain on secondary adjustments and further guidance from the Brazilian Federal Revenue Service is needed.

  • A bill is expected to be proposed in the coming months…

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