On June this year, Law 14,596/2023 was enacted, introducing major changes the Brazilian Transfer Pricing Scenario, with highlights to the new calculation methods and alignment with the OECD guidelines on the subject, also introducing the arm’s length principle, which are relevant to the Brazilian companies that have transactions with related parties overseas.

Last week, after a consultation period that followed the introduction of the above-mentioned law, it was published Normative Instruction 2,161/23, bringing further detail on the application of the rules.

The new legislation is mandatory as from January 1, 2024, and companies can early adopt it for 2023, outlining such option until December this year.

Our team is at your disposal to discuss the implications of the new regulations.