Home » Alert on Transfer Pricing in Brazil N° 002-2023-BR

Alert on Transfer Pricing in Brazil N° 002-2023-BR

Participation in the Public Consultation for the Regulation of the New Transfer Pricing Law:An Opportunity to Influence Fiscal Policy

São Paulo, July 6, 2023

The public consultation on the Normative Instruction that will regulate the new transfer pricing law is an important step in the incorporation of the arm’s length principle into the Brazilian legal system, as expressed in Law No. 14.596, of 2023. This is a crucial phase that involves the participation of various stakeholders.

Companies from different sectors, which will be directly impacted by the legislation, have the opportunity to present their practical comments and queries.

Tax professionals, with their technical expertise, can contribute with their technical vision on the impacts and possible improvements in the regulation.

Academic institutions can offer a theoretical and analytical perspective, helping to understand the possible macroeconomic effects of legislation.

Non-governmental organizations and the general public contribute varied visions, providing a diversity of opinions that can enrich the construction of the Normative Instruction.

We should also mention the need for simplification for low value-added intra-group service transactions, which can facilitate management for many companies.

It is important to have a mechanism for continuous review and updating of the Regulations, in order to follow changes in the business environment and respond to emerging needs.

The contribution of all interested parties is essential for the improvement of tax rules, and we encourage everyone to participate in this process.

Comments and suggestions should be sent by 07/25/2023 to cotin.df.cosit@rfb.gov.br.

The new transfer pricing law, which we are discussing, has its mandatory application as of 2024. However, taxpayers who wish to anticipate the effects of the new legislation have the option to adhere as early as 2023.

In view of the new context and the importance of participation in this process opened by Receita Federal do Brasil, we are available to discuss the issues highlighted in the consultation.


TP Consulting Brazil

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