The proposed regulations intend to restrict the mark up applicable to intermediation services.The proposed regulations include further details on the benefit tests. Besides dealing with transfer pricing matters related to services, the rules also cover the application of the withholding tax on intermediation services. A completely new set of regulations are proposed for advance pricing agreements (APAs), with some limitations being proposed that had not been anticipated in former publications by the tax authorities. On 28 August 2024, the Brazilian Federal Revenue Service (RFB) published a public consultation to collect comments and suggestions on the proposed regulations to implement the transfer...