Brazil has published Normative Instruction No. 2.246 of 30 December 2024, which contains amendments to Normative Instruction RFB No. 2.161 of 28 September 2023, which established the regulations for the country's transfer pricing regime. This includes a new paragraph 8 under Article 37 of Normative Instruction RFB No. 2.161, which provides that for contracts used for recurrent or long-term deliveries, taxpayers must assess, for the purposes of complying with the arm's length principle, whether the price-setting mechanism is in accordance with market practices on the date the contract is entered into, taking into account the type of commodity. For this...