Brazil Introduces New Transfer Pricing Regime

Brazil has published Provisional Measures No. 1.152 of 28 December 2022, which provides for the introduction of a new transfer pricing regime that is in line with OECD standards. Some of the main points of the Provisional Measures are summarized as follows:

Purpose and Scope

The Provisional Measure amends the Corporate Income Tax (IRPJ) and Social Contribution on Net Income (CSLL) legislation to provide for transfer pricing rules that apply in determining the IRPJ and CSLL calculation bas…