Brazil’s revenue authority has launched a public consultation on a proposed amendment to its transfer pricing rules on 27 November 2024.
The proposed amendment concerns Normative Instruction RFB No. 2,161 of September 28, 2023, addressing regulations concerning the registration of controlled commodity transactions. The deadline to receive comments is 11 December 2024. Submissions must be sent to cotin.df.cosit@rfb.gov.br in PDF format.
Transfer pricing rules are used for tax purposes to allocate profits or losses among the various entities of a multinational business group. Law No. 14,596, of June 14, 2023, incorporated the arm’s length principle into the Brazilian legal system, and the application of this new model is mandatory as of 2024.
The revised regulations mandate taxpayers to register controlled commodity transactions and disclose details with penalties for noncompliance.
Last year, Brazil introduced new transfer pricing rules aligned with OECD standards, adopting the arm’s length principle.
Earlier, on 30 March 2023, Brazil’s Lower House of Congress approved legislation that brought significant changes to the country’s transfer pricing system.
