Transfer Pricing Report - Brazil
Take Control of Transfer Pricing Brazil for Tax Clarity & Total Tax Compliance.
Brazil has redefined its Transfer Pricing system to align with the OECD Transfer Pricing Guidelines, introducing significant documentation and benchmarking obligations. Our experts deliver tailored Transfer Pricing studies that ensure compliance, transparency, and audit-readiness under the new Brazilian rules.
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Ensure Compliance Through Brazil’s New OECD Transfer Pricing Framework
Brazil has entered a new era of Transfer Pricing compliance following the enactment of Law 14,596/2023, officially aligning its domestic Transfer Pricing rules with the OECD Transfer Pricing Guidelines. This reform marks a fundamental shift from Brazil’s long-standing formula-based system to an arm’s-length principle approach — a major step toward international harmonization.
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We combine international Transfer Pricing expertise with local Brazilian tax insight to help corporations navigate documentation, benchmarking, and dispute prevention.
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Answers to Your Transfer Pricing Concerns Brazil
Get clarity on the most common questions our clients ask about international transfer pricing services.
Still Have Questions?
Is Transfer Pricing documentation mandatory in Brazil?
Yes, Brazil requires Transfer Pricing documentation for cross-border related-party transactions under the New TP Law (Law 14,596/2023).
A complete Transfer Pricing Study ensures compliance with Brazil’s OECD-aligned rules.
Does Brazil follow OECD Transfer Pricing Guidelines?
Yes, Brazil officially adopted OECD methods and comparability standards starting in 2024.
This ensures Transfer Pricing in Brazil aligns with global arm’s length principles.
Which transactions require a Transfer Pricing Study in Brazil?
Imports, exports, services, royalties, IP, and intercompany financing must be documented.
A Transfer Pricing Study validates arm’s length pricing for entities operating in Brazil.
How do Brazil’s new TP rules differ from the old fixed-margin system?
Brazil replaced fixed margins with full OECD methods, comparability testing, and economic analysis.
This modernizes Transfer Pricing in Brazil and improves global alignment.
How does benchmarking work under Brazil’s new TP framework?
Benchmarking compares related-party transactions with independent market comparables globally.
This ensures Transfer Pricing outcomes in Brazil meet arm’s length expectations.
What penalties apply for TP non-compliance in Brazil?
Brazil may impose high penalties, adjustments, and interest for missing or inaccurate documentation.
A robust Transfer Pricing Study reduces audit exposure in Brazil.
How often should Transfer Pricing documentation be updated in Brazil?
Annual updates are required, especially under Brazil’s new OECD-aligned regime.
Regular updates keep Transfer Pricing compliance accurate in Brazil.
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