Brazilian Senate Approves New Transfer Pricing Rule and Provisional Matter May Shortly be Converted into Law
As previously reported, through Provisional Measure #1,152 (of December 28, 2022), amendments were made to the Corporate Income Tax (IRPJ and CSLL) legislation with regard to the rules of Transfer Pricing (TP) in Brazil. Such measure is considered to be an approximation of Brazil to the OECD, being part of the changes foreseen for the country's entry into the Organization.
Since it is a Provisional Measure, the next step of such regulation to enter in force as law, that it has being going through since March 2023, is the text to go under analysis before the Brazilian Chamber of Deputies. Recently, on the 10th of May, such text was approved by the referred chamber.
The main change introduced by the Brazilian Senate would be the elimination of the deductibility restrictions related to royalties and services remitted to entities or individuals located in tax havens or privileged tax jurisdictions, among other minor changes.
Currently, the text is under the analysis of the Brazilian President, and it is expected that such MP will be converted into law very shortly.
