TP Ticker – December 2019

Report on Aligning Brazilian TP with the International Standard
On 18 December 2019, the OECD and Brazil’s Federal Revenue Authority published a first report on their joint project addressing the misalignment between the Brazilian transfer pricing regulations and the international standard.  The report comes to the conclusion that Brazil should aim for full alignment – either immediately or gradually – with the international standard.  This refutes discussed options that would only entail a partial alignment or the option for the taxpayer to choose between either the existing Brazilian regulations or the international standard.  In a next phase of the project, the steps for implementation of the full alignment will be explored further.
The detailed report “Transfer Pricing in Brazil: Towards Convergence with the OECD Standard” can be found on the website of the OECD here: https://www.oecd.org/ctp/transfer-pricing/brazil-identifies-a-clear-pathway-for-aligning-its-transfer-pricing-framework-with-the-oecd-standard.htm