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Introduction of OECD Transfer Pricing Standards in Brazil
On September 28th, 2023, the Brazilian tax administration (Receita Federal do Brasil; RFB) issued the long expected Normative Instruction No 2,161/2023 further regulating Law 14,596/2023 on the introduction of the new Brazilian Transfer Pricing Regime in line with OECD standards, applicable as of January 1st, 2024, with an option for early and retroactive application as of January 1st, 2023, to be elected until end of 2023.
1. Background
From a big-picture perspective, the application of OECD Transfer Pricing Standards may be considered as part of Brazil’s greater aim to join the OECD as a full member. Since its formal application in June 2017, several respective steps were taken and, on June 10th, 2022, the OECD council at ministerial level adopted a “Roadmap for the OECD Accession Process of Brazil” setting out the “Shared Values, Vision and Priorities”, “Obligations of OECD Membership” as well as core principles for the “Technical Reviews by OECD Committees”. Within these core principles to be reviewed by 26 OECD committees, “eliminating double taxation through ensuring the primacy of the arm’s length principle, as set out in the OECD’s Transfer Pricing Guidelines for Multinationa...