On 10 May 2023, the Brazilian Senate (upper house of Congress) approved Conversion Bill No. 8 of 2023, which converts Provisional Measure No. 1.152 of 28 December 2022 (previous coverage) into law for the introduction of a new transfer pricing regime that is in line with OECD standards. The text as approved by the Senate is in line with the text as approved by the Chamber of Deputies (lower house) on 30 March 2023. As previously reported, this largely follows the text of the original Provisional Measure, although there are some notable amendments including that (a) royalties paid to persons...