Resources providing insights on the potential impacts of the Brazilian tax authority's issuance of Provisional Measure 1152.
On December 28, 2022, the Brazilian government issued Provisional Measure No. 1,152 (the ‘‘Provisional Measure’’) bringing Brazil’s historical, formula-based transfer pricing rules ever closer to an arm’s length standard consistent with the OECD Guidelines. MNEs are working quickly to understand the practical transfer pricing and international tax consequences of these changes.
The Provisional Measure incorporates several very important features of the OECD transfer pricing framework including:
Popular category topics
Brazilian Transfer Pricing: Timing Is Everything
In this article, the authors address changes to the Brazilian transfer pricing system that include becoming compliant with the OECD Guidelines.Download PDF
U.S. Foreign Tax Credit Regulations: The Last Straw for Brazil's Transfer Pricing Regime?
In this article, the authors examine potential double taxation of U.S. multinationals operating in Brazil resulting from the U.S. final foreign tax credit regulations and Brazil’s transfer pricing regime, which is not aligned with the arm’s-length standard. The article considers whether this outcome might accelerate Brazil’s accession to the OECD and adoption of the arm’s-length standard.Download PDF