Since the news of the Brazilian request to accede to the OECD broke out, much has been speculated about the future of the Brazilian TP approach. Brazil is historically one of the major economies to deviate from the OECD Guidelines – and its approach has been severely criticized for that. Thus, it is no surprise…

On 11 July 2019, the event “Global Transfer Pricing Standard and Brazilian Approach: The Way Forward” took place in Brasilia, in which the Organization for Economic Cooperation and Development (OECD) and the Brazilian Federal Revenue Office (RFB) presented the main discrepancies between the OECD Transfer Pricing Guidelines (TPG) and the Brazilian transfer pricing rules, an…

Brazilian Transfer Pricing Rules have been in force since 1996. When introduced, the intent of the legislator was clearly the prevention of tax evasion through manipulation of prices, though setting up a methodology easy to apply and to enforce. It is common sense that the methodology facilitates the fiscalization of tax officials and provides certainty…