On 14 June 2023, the president Luiz Inácio Lula da Silva signed the Law No. 14,596 adopting Provisional Measure No. 1,152, which enacts significant changes to the Brazilian transfer pricing system that is aligned with the guidelines provided by the Organisation for Economic Co-operation and Development (OECD).
As part of the implementation of the new Brazilian transfer pricing framework, the PM 1552/22 was published on 28 December 2022. It was approved by both the Lower House of Congress and the Federal Senate, and then submitted to the President of Brazil for approval on 25 May 2023. On 14 June 2023, PM 1.152/22 was transformed into Law 14.596/23 after being signed by the Brazilian President without any significant change to the text approved by the Brazilian Congress.
Brazilian taxpayers could choose to adopt the new TP system this year, aligned with OECD guidelines. To do this, taxpayers must notify the Brazilian Tax Authority (RFB) between 1 September and September 2023. The new TP system will be mandatory for all taxpayers from 1 January 2024.
