The commodity concept under the proposed transfer pricing system would follow market practice and the definition of intangible would align with the OECD Transfer Pricing Guidelines. The new system would require taxpayers to present the local and master files, together with the already required country-by-country report. Questions still remain on secondary adjustments and further guidance from the Brazilian Federal Revenue Service is needed. A bill is expected to be proposed in the coming months. Taxpayers that may be affected by the new transfer pricing system should continue to follow the discussions on the new system.On 29 June 2022, the Brazilian...