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Brazil's New Transfer Pricing Regime Converted into Law

20 June 2023

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Approved Changes

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Brazil

Brazil has published Law No. 14.596 of 14 June 2023 in the Official Gazette, which converts Provisional Measure No. 1.152 of 28 December 2022 into law for the introduction of a new transfer pricing regime that is in line with OECD standards (previous coverage). The text of the Law follows the text of the original Provisional Measure, although there are some amendments including: The removal of the restriction on the deduction amounts paid for royalties and for technical, scientific, administrative, or similar assistance to a low-tax jurisdiction or beneficiaries of a privileged tax regime, although it is maintained that such...