February 27, 2023

New Brazilian Transfer Pricing Rules – Regulation issued by Normative Instruction No. 2,132/2023:


On February 24, 2023, Normative Instruction No. 2,132 was published by the Brazilian Federal Revenue Office, establishing the regulation of the taxpayer's election to apply the New Transfer Pricing Rules provided for in Provisional Measure (PM) No. 1,152/2022 to the controlled transactions in 2023.

Normative Instruction No. 2,132/2023 provides for (i) the formalization and effects of the election, (ii) adjustments to the Brazilian Corporate Income Tax (CIT) taxable base, and (iii) the deductibility of royalties and technical, scientific, administrative or similar assistance.

For further details on the main aspects of the New Transfer Pricing Rules, see our Legal Update Brazil and the International Transfer Pricing Standards: Provisional Measure 1,152/2022.

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