Brazil’s New Transfer Pricing Act


This e-book contains the full text (English and Portuguese) of Law No. 14,596 of June 14, 2023 (Brazil’s New Transfer Pricing Act).


Law No. 14,596, of June 14, 2023, radically changes how transfer pricing is treated in Brazil by embracing the arm’s-length principle and the OECD standards.

By adopting the arm’s length principle, the law creates a new world for Brazilian companies subject to transfer pricing. Chapters of the law deal with a variety of transfer pricing issues such as controlled comparability analysis, acceptable methods and their selection by the taxpayer, commodities, tax adjustments, transactions involving intangibles, hard-to-value intangibles, intragroup services, cost-sharing agreements, business restructuring, debt transactions, intragroup guarantees, centralized treasury management agreements, insurance contracts, supporting documentation, penalties, transfer pricing ruling request procedure, and many more.

1 review for Brazil’s New Transfer Pricing Act

  1. Mark P. Jones

    Very helpful!

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