🌐 Your Guide to the Latest Brazil's Transfer Pricing Rules 🌐

Partner with us for Seamless Compliance to Enhance Your Client Base!

Brazil's alignment with OECD guidelines through Normative Instruction (NI) 2,161/23 is a landmark change in transfer pricing legislation, introducing a host of new requirements and flexibility options. Understanding these updates is pivotal and we're here to support and partner.

✨ Key Updates - Brazil's alignment with OECD guidelines:

1. Flexibility in Adoption: Businesses can now choose to apply these rules retroactively from January 1, 2023, or opt to start on January 1, 2024. Decision to be made via the Brazilian tax authorities' (Receita Federal Do Brasil - RFB) online portal by December 31, 2023.

2. Documentation Requirements: Tailored to the inter-company transaction volume, with specific guidelines for Master and Local files. Key points being:

   • For transactions over BRL (Brazilian Real) 500 million, complete OECD-compliant Master and Local files are required.

   • For those between BRL 15 million and BRL 500 million, a simplified Local file is sufficient.

   • Entities with transactions below BRL 15 million are exempt from detailed documentation but must observe the arm's length principle.

3. Language and Reliability Enhancements: The RFB’s acceptance of the Master file in English demonstrates a move towards a more cohesive transfer pricing framework

4. Royalties Adjustment: Royalty calculations have evolved, with the 1-5% safe harbor removed in favor of OECD standards-based evaluations. We are specialists in this area, take advantage of our expertise.

5. Advanced OECD Methods: For complex transactions and inter-company transaction aggregation, the refined transactional methods will offer more applicability.

🔍 Benefits of Partnering with Us:

1. Deep Industry Experience: We have a proven track record in delivering OECD-compliant documentations, backed by our history of supporting clients through similar transitions.

2. Benchmarking Expertise: We are specialists in this area, take advantage of our expertise to transition to OECD based requirements, with special emphasis on inter-company royalty payments.

3. Expert Team at Your Service: Our seasoned professionals are equipped with the expertise necessary to navigate the nuances of the updated regulations.

4. Access to Specialized Tools: We provide exclusive access to specialized databases to support various transaction types, giving you a refined compliance edge.

5. Timely and Informed Delivery: We ensure your transition is smooth with regular updates and timely deliveries.

6. Technological Efficiency: Our use of advanced Excel automation techniques optimizes the efficiency of the transfer pricing process.

👥 Going the Extra Mile:

1. Tailored Guidance: We provide the handholding and specific guidance needed during this crucial transition.

2. Responsive Support: You can count on us for ad hoc assistance whenever the need arises.

3. Strategic Empowerment: Our strategic support will enable you to make informed decisions on transfer pricing structure selection.

Connect with us now and navigate the new regulations with ease and confidence!