Description
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.
Mark P. Jones –
Very helpful!