Brazil: Law that establishes new transfer pricing rules is published

15 Jun 2023    1 minute read

In brief

As detailed below by the tax experts from Trench Rossi Watanabe* with whom we have executed a strategic cooperation agreement for consulting on foreign law, Law No 14,596, originated from Provisional Measure No. 1,152/2022, was published this Thursday (06/15/2023) to introduce new transfer pricing rules in Brazil.

Contents

The new Law reproduces the wording of Bill of Law No 08/2023 previously approved by the Senate, which means that there were no vetoes and that Law No. 14,596 enters into force on January 1, 2024, except for taxpayers who opt to anticipate the effects of the new rules as from January 1, 2023.

The changes introduced by Law No 14,596 are aligned with the OECD standards, representing one of the key developments for Brazil to become a member of the Organization.

The expectation is that in a short period of time the Brazilian Federal Revenue will publish Normative Rulings to further regulate the matter.

More details about the new Brazilian transfer pricing rules and their potential impacts to our clients can be found in this link, which has materials previously published by our transfer pricing experts.

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Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

Contact Information
Clarissa Machado
Partner at BakerMcKenzie
Sao Paulo
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clarissa.machado@trenchrossi.com
Simone Musa
Partner
Sao Paulo
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simone.musa@trenchrossi.com
Reinaldo Ravelli Neto
Partner at BakerMcKenzie
Sao Paulo
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reinaldo.ravelli@trenchrossi.com

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