Relations internationales et fiscalité

OECD and Brazil work together to align Brazil's transfer pricing rules to international standard


13/04/2022 – The OECD and Brazil's Receita Federal (RFB) held a joint high-level event on 12 April 2022 in Brasília to present the key features of Brazil’s proposed new transfer pricing system.


The outcome of the joint project between OECD and RFB, which has been supported by the United Kingdom Foreign, Commonwealth and Development Office (FCDO) since its launch in February 2018, will be a new transfer pricing framework for Brazil, aligned to the OECD standard.


In welcoming this important step forward, Paulo Guedes, Brazil’s Finance Minister noted: “As we successfully converge with the OECD standard, we are not only celebrating a key step forward but also addressing two main challenges: the harm of excessive taxation and double taxation that prevent investments; and the damage of tax avoidance through the transfer of profits to locations providing for a more favourable taxation. This is fundamental because it allows us to gain in efficiency, with effective allocation of investments across this global community that is embracing itself through the convergence of these practices.”


Yesterday’s announcement follows the joint statement of the OECD and RFB in July 2019 and subsequent announcements in December 2019 on the publication of an in-depth report identifying a clear pathway for Brazil to converge with the OECD transfer pricing standard. Throughout 2020 and 2021, efforts continued to finalise the tax policy design of the new system, together with capacity building activities.


“There were and still are some elements that we need to improve in order to avoid double taxation and double non-taxation, which are elements that are very harmful to our objectives in terms of transfer pricing and our alignment with OECD guidelines. We believe that overcoming these elements will make Brazil more attractive to foreign investment, and will allow for greater integration of the country into global economic chains and the development, expansion and protection of its tax base,” said Julio Cesar Vieira Gomes, RFB’s Special-Secretary.


“This alignment is a transformational change that will support Brazil’s development objectives” added Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration. “It will facilitate the smooth implementation of the Two-Pillar Solution to address the tax challenges of the digitalisation of the economy, with significant revenue potential for Brazil. We stand ready to provide support in making the new system operational.”


The United Kingdom’s Acting Ambassador to Brazil, Melanie Hopkins, added: “We are pleased to co-operate and support this transformational policy change project for Brazil. We hope for swift adoption and implementation of the new system.”


A replay of the event is available in both Portuguese and English.


Further information on the project can be found at


Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (CTPA), or to the CTPA Communications Team.


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