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 also been involved in a consultation with the OECD on new transfer pricing rules that aim to bring Brazil’s rules further in line with the OECD transfer pricing guidelines. 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. Discussions are being held with various business sectors that will be affected by the changes and a legislative package will then be finalised and presented to Congress for approval.

For some time, businesses in Brazil and the UK have been urging the governments to conclude a double taxation agreement, with a view to boosting cross-border trade and investment. The agreement is likely to allocate taxing rights to cross-border income; provide for the elimination of double taxation; and set out the procedures for resolution of disputes concerning taxation issues.