Brazil Consulting on Transfer Pricing Regulations for Intragroup Service and Procedure for Unilateral APAs

On 29 August 2024, Brazil's Federal Revenue Service (RFB) announced the launch of a public consultation on draft normative instructions on transfer pricing regulations for intragroup services and the procedure for unilateral advance pricing agreements under Brazil's new transfer pricing regime. As previously reported, Brazil's new transfer pricing regime was introduced by Provisional Measure No. 1.152 of 28 December 2022, which was converted into law by Law No. 14.596 of 14 June 2023. The re…