Brazil passes major indirect tax reforms 

December 23, 2023

On 20 December 2023, Brazil passed Constitutional Amendment No. 132 of 20 December 2023, introducing major indirect tax reforms.  These reforms will replace or unify several existing indirect taxes with new tax measures. The taxes that are

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Chile signs EU Trade Agreement & approves DTA protocol with Brazil

December 14, 2023

On 13 December 2023, Chile became the first country in the Latin American region to conclude with the European Union EU an Advanced Framework Agreement and an Interim Trade Agreement to strengthen political cooperation and foster trade and

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Brazil tax reform brings challenges to service sectors

December 14, 2023

The new Brazilian transfer pricing rules align with the OECD standard and are a radical change to the analysis of intra-group transactions, and offer several implementational challenges. Besides, the tax reform (PEC 45/2019) is being discussed in

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Brazil proposes to modify interest on net equity for 2024 

December 14, 2023

On 30 November 2023 and 5 December 2023, Brazil’s Valor Econômico newspaper published a report stating that the Ministry of Finance of Brazil has completed the draft of a new proposal to amend the Interest on Net Equity (INE) mechanism. The

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Brazil releases normative instruction for its new transfer pricing rules

October 17, 2023

On 28 September 2023, Brazil published Normative Instruction Nº 2,161 (IN 2,161/23) that governs Brazil’s recently established new transfer pricing law. The new legislation explicitly adopts the arm's length principle into the Brazilian legal

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Brazil gazettes provisional measure for the taxation of investments in investment funds

September 08, 2023

On 28 August 2023, Brazil published Provisional Measure No. 1,184 (MP) outlining the taxation of investment funds in Brazil and introducing a periodic taxation approach for both closed-end and exclusive funds. Key proposals under the MP are

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IMF Report looks at the Economy of Brazil

August 06, 2023

On 31 July 2023 the IMF issued a report following talks with Brazil under Article IV of the IMF’s articles of agreement. Although economic growth in the first part of 2023 has been buoyed by strong agricultural output, manufacturing and

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Brazil: President signs OECD-aligned transfer pricing rules

June 25, 2023

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

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Brazil: Federal Senate approves OECD-aligned transfer pricing rules

May 20, 2023

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

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Brazil publishes law extending certain CFC benefits

April 20, 2023

On 13 April 2023, Law No. 14.547 transposing Provisional Measure 1148/2022 into law was published in the Brazilian Official Gazette, which extends certain benefits in regard to the controlled foreign company (CFC) rules under Law 12,973/14. Under

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Brazil: Lower House passes transfer pricing reform measure

April 10, 2023

On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer

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Brazil publishes law reducing WHT rate on cross-border payments

March 08, 2023

On 28 February 2023, the government of Brazil has published Law no. 14,537, which reduces the withholding tax rates for cross-border payments related to travel to foreign individuals or entities residing or having their registered offices

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Brazil issues normative instruction establishing new transfer pricing regulations for 2023

March 05, 2023

On 24 February 2023, the Brazilian Federal Revenue Office published the Normative Instruction No. 2.132 which establishes the regulation of the taxpayer's choice to apply the new transfer pricing rules according to Provisional Measure (PM) No.

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Brazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines

December 31, 2022

On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,

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Brazil and the UK Begin Negotiations for a Double Tax Agreement

September 09, 2022

Following the completion of exploratory talks, the UK and Brazil are to hold a first round of negotiations on a double taxation agreement from 12 to 16 September 2022. Brazil began accession discussions with the OECD on 25 January 2022 and has

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BRICS Summit Declaration Notes Progress on Tax and Customs Cooperation

June 28, 2022

  Following the virtual BRICS summit held on 23 June 2022, the Beijing Declaration emphasised the need to cooperate to promote economic recovery. The BRICS group of emerging powers – Brazil, Russia, India, China and South Africa – has

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Brazil: Government proposes new transfer pricing system

April 18, 2022

On 12 April 2022, the tax authority and Organisation for Economic Co-operation and Development (OECD) met to discuss Brazil’s proposal for a new transfer pricing (TP) system. The Brazilian Economy Minister, Paulo Guedes, said that the creation

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Brazil and OECD present outline of new transfer pricing rules

April 15, 2022

On 12 April 2022 an event was held to present the outline of the new transfer pricing rules drafted by Brazil following a consultation process with the OECD. After Brazil had expressed the intention to become a full OECD member, Brazil and the

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