Transfer Pricing in Brazil: Towards Convergence with the OECD Standard


TP brazil report cover 

This report is an outcome of the joint project on transfer pricing between OECD and Receita Federal do Brasil (RFB). It contains the findings of the in-depth analysis of similarities and differences between the transfer pricing framework currently in place in Brazil as compared to the OECD guidance (OECD Transfer Pricing Guidelines for Multinational Enterprise and Tax Administrations), which is the international consensus on transfer pricing. The report also explores the options for Brazil to converge with the OECD transfer pricing standard while enhancing the positive attributes of the existing framework.


Published: 18 December 2019


In February 2018, the OECD and Brazil launched a joint project to examine the similarities and divergences between the Brazilian and OECD transfer pricing approaches to valuing cross-border transactions between associated enterprises for tax purposes. This builds on Brazil’s robust engagement in the OECD’s tax work. Brazil has been actively participating in the OECD tax work since joining the Global Forum on Transparency and Exchange of Information for Tax Purposes in 2010 and since 2013 as a member of the G20/OECD BEPS Project, which had a substantial focus on transfer pricing. In 2017, Brazil also expressed interest in initiating the process to join the OECD.

The launch of the project is an important milestone in deepening the dialogue between the OECD and Brazil on transfer pricing matters. In the light of the findings of this assessment, the project explored the potential for Brazil to move closer to the OECD transfer pricing standard, which is a critical benchmark for OECD member countries, and followed by most countries around the world.


Key dates

30/07/2020 - OECD and Brazil's federal revenue authority invite taxpayer input on transfer pricing issues relating to the design of safe-harbour provisions and other comparability considerations - Deadline 30 October 2020


18/12/2019 - High-level launch event for the joint report Transfer Pricing in Brazil: Towards Convergence with the OECD Standard in Brasilia, Brazil.


11/07/2019 – The OECD and RFB issued a joint statement at the high-level event held on 11 July 2019 in Brasília, Brazil, to present the outcomes of the 15-month work programme carried out by OECD jointly with RFB. This one-day-long event hosted by National Confederation of Industry (CNI) brought together almost 300 senior officials from the Brazilian government, the OECD, representatives of MNEs operating in Brazil, and government representatives from Brazil's major trading and investment partners.


28/02/2018 - The OECD and Brazil launched a joint project to examine the similarities and gaps between the Brazilian and OECD approaches to valuing cross-border transactions between associated firms for tax purposes. The project aims to assess the potential for Brazil to move closer to the OECD’s transfer pricing rules, which are a critical benchmark for OECD member countries and followed by countries around the world.







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