In February 2018, the OECD and Brazil started a joint project to analyze the similarities and differences between Brazilian legislation and the transfer pricing (“TP”) frameworks to assess cross-border transactions between associated enterprises from a tax standpoint. This project is within the scope of Brazil’s initiative to engage with the OECD in tax-related projects, and, in a broader respects, consistent with Brazil’s interest in initiating the process to join the OECD.
Stages of the Project
The project had three stages:
- Stage 1: preliminary analysis of the legal and administrative framework of Brazil’s transfer pricing rules;
- Stage 2: assessment of the strengths and weaknesses of Brazil’s existing transfer pricing rules and administrative practices; and
- Stage 3: options for alignment with the OECD transfer pricing standard.
By Ivan Tauil and Thais Rodrigues via Mondaq