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Brazil Providing Exceptional Exclusion from Classification as Low-Tax for Countries Making Significant Investment in Brazil

24 October 2024

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Approved Changes

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Brazil

Brazil has published Decree No. 12.226 of 18 October 2024 in the Official Gazette, which establishes that countries (jurisdictions) may request an exclusion from the classification as providing favorable taxation or a privileged tax regime if they promote national development through significant investments in Brazil. In particular, the Decree regulates the provisions of Article 24-C of Law No. 9.430 of 27 December 1996, which authorizes the exceptional exclusion from the classification provided for, respectively, in Articles 24 and 24-A of the aforementioned Law. The classification is applied in relation to Brazil's new transfer pricing regime. Brazil's new transfer pricing regime...