Transfer pricing

Joint Brazil-OECD Transfer Pricing Project


Background | Material | Key dates



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 OECD/G20 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 was an important milestone in deepening the dialogue between the OECD and Brazil on transfer pricing matters. In 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.

The work carried out on this project resulted in conclusions that the current Brazilian system undermines the fiscal and development interests of the country. It was concluded that alignment with the international standard was the best option for Brazil. Full alignment was considered necessary because, otherwise, significant gaps would remain in the system with negative effects on tax certainty, the compliance burden, as well as risks of persisting double taxation and loss of tax revenue.

The work that was spearheaded by RFB and benefited from the involvement of all stakeholders, including business and academia in Brazil, led to the publication of Provisional Measure No. 1,152 on 29 December 2022, unveiling the text of the new transfer pricing rules, which is currently under consideration in the Brazilian Congress.




The New Transfer Pricing Framework: Enhancing Brazil’s Tax System while Fostering Trade and Investment

This brochure contains an update on the status of the implementation of a new transfer pricing framework in Brazil, which aims to align Brazil’s transfer pricing framework to the international standard. It includes a brief discussion of the primary legislation reflected in Provisional Measure 1,152/22, which is currently being considered by Congress.


Published: 5 April 2023

TP brazil report cover 

Transfer Pricing in Brazil: Towards Convergence with the OECD Standard

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


Transfer Pricing in Brazil: Towards Convergence with the OECD Standard - Highlights

This brochure provides the highlights of the Joint Report "Transfer Pricing in Brazil: Towards Convergence with the OECD Standard” featured above. It contains an overview of the project and summarises the key information from the report.


Published: 18 December 2019

Key dates

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.


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. 


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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