With EY transfer pricing and tax professionals
Brazil transfer pricing update: potential alignment with the OECD standard
In December 2019, the Organisation for Economic Co-operation and Development (OECD) and the Brazilian Revenue Authority (Receita Federal do Brasil – RFB) presented a detailed report on their joint project launched in 2018 to examine the similarities and divergences between the Brazilian and the OECD transfer pricing approaches. Historically, Brazil’s approach to transfer pricing has been somewhat unique, with a framework that differs significantly from standards applied more broadly in the international tax community. The OECD/RFB project was intended to assess the strengths and weaknesses of Brazil’s transfer pricing framework, and the associated report outlines options for aligning Brazil’s transfer pricing rules with the OECD standard.
The potential alignment of Brazil’s transfer pricing rules towards the OECD standard would be a very important development to the international business community. Among other things, overcoming differences in transfer pricing could help the US and Brazil take an important step towards negotiating an income tax treaty. Brazil’s alignment with the OECD transfer pricing guidelines would also help it clear a hurdle in the process of joining the OECD – a process in which Brazil expressed its interest starting in 2017.
In this webcast, our panelists will provide an update on transfer pricing in Brazil and discuss considerations for 2020 and beyond. Topics to be addressed include: