Today, on September 29, 2023, the Brazilian Official Gazette (DOU) published Normative Instruction RFB 2.161/23, which regulates Brazil’s new transfer pricing rules as set forth in Law 14.596/23.
Important: the Normative Instruction extends the deadline for taxpayers to elect early adoption of the OECD TP guidelines to December 31, 2023.
This means that MNEs operating in Brazil still have time to analyze the optimal transfer pricing strategy option for FY 2023. Our expert team is here to help you during this crucial transition period.
Davi.santana@basefirma.com – Partner, BaseFirma Brazil
Chad.martin@basefirma.com – Denver Office Lead, BaseFirma USA
Read the full Brazilian Official Gazette here (and find the Normative Instruction on page 107).