Brazil: General View Of The Project “Transfer Pricing In Brazil”

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


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