
Brazil recently proposed a measure that seeks to align its transfer pricing rules with OECD guidelines. The rules will have significant compliance and financial implications for companies that do business in the country. Brazil’s transfer pricing regulations have historically diverged from OECD practices in ways that have resulted in double taxation or under-taxation, loss of revenue for the country and greater tax complexities for multinationals. The new rules go into effect in January 2024, but taxpayers can choose to begin following them now.