Brazil's Federal Revenue Department (RFB) has issued Normative Instruction RFB No. 2161 of 28 September 2023, which regulates the country's new transfer pricing regime. As previously reported, Brazil's new transfer pricing regime was introduced by Provisional Measure No. 1.152 of 28 December 2022, which was converted into law by Law No. 14.596 of 14 June 2023. The new law expressly incorporates the arm's length principle into the Brazilian legal system in accordance with OECD standards. The new regime is mandatory from 2024, although taxpayers may elect to apply the new regime for 2023 as well. The Normative Instruction covers: General...