On 10 May 2023, the Brazilian Federal Senate approved legislation addressing the new transfer pricing which was published on 29 December 2022.

This approval is one of the last steps to implement a transfer pricing system in Brazil according to the guidelines set by the OECD. Brazilian taxpayers could choose to adopt the new TP system this year. To do this, taxpayers must notify the Brazilian Tax Authority (RFB) between September 1 and September 30, 2023. The new transfer pricing (TP) system will be mandatory for all taxpayers from 1 January 2024.