The new transfer pricing system would have a significant impact on taxpayers not only because more transactions would be subject to a transfer pricing analysis but also because the current formulary transfer pricing approach adopted by Brazil would be replaced by the arm’s length principle. Taxpayers may want to evaluate the impact the new system may have on their operations and monitor the development of this proposal, as well as its progress through the Brazilian Congress. On 12 April 2022, the Brazilian Tax Authority (RFB) and Organisation for Economic Co-operation and Development (OECD) met to discuss Brazil’s proposal for a...