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OECD Notes Presentation of Brazil's Proposed Transfer Pricing System to Align with OECD Standards

15 April 2022

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Proposed Changes

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Brazil-OECD

The OECD has issued a release following a presentation of Brazil's proposed new transfer pricing system, which is aligned with OECD standards. The new system includes the application of the arm's length principle to all controlled transactions in general, the allowed application of the five standard transfer pricing methods as well as other methods if appropriate, new rules for comparability analysis, specific rules for intangibles, intragroup services, cost contribution arrangements, etc. Next steps will include consultations with stakeholders, the finalization of the legislative package for the new transfer pricing system, and the submission of the package in Congress for approval....