KPMG report: Transfer pricing in Brazil
A report on how multinational enterprises must quickly work to analyze and carefully document their operations for transfer pricing purposes
Brazil officially shifted from its traditional, formula-based transfer pricing system to an arm’s length standard largely consistent with the 2022 OECD Transfer Pricing Guidelines on January 1, 2024.
This significant shift from the previous system, which relied upon Brazil-specific transfer pricing methods based on standard fixed gross margins or mark-ups, has left many taxpayers grappling with the implications. While taxpayers had the option to apply the new rules to the 2023 tax period, most taxpayers opted for the mandatory adoption in 2024 and are currently in the process of understanding the functions performed assets used and risks assumed by their Brazil operations to apply this new transfer pricing regime.
Read a July 2024 report* prepared by KPMG LLP that discusses how multinational enterprises operating in Brazil must quickly work to analyze and carefully document their Brazil operations for transfer pricing purposes and try to minimize year-end transfer pricing adjustments.
* Reproduced with permission from Tax Management International Journal, 7/10/2024. Copyright @ 2024 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com