Introduction of OECD Transfer Pricing Standards in Brazil

On September 28^th, 2023, the Brazilian tax administration (Receita Federal do Brasil; RFB) issued the long expected Normative Instruction No 2,161/2023 further regulating Law 14,596/2023 on the introduction of the new Brazilian Transfer Pricing Regime in line with OECD standards, applicable as of January 1^st, 2024, with an option for early and retroactive application as of January 1^st, 2023, to be elected until end of 2023.

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