Sanctioned by Law, MP N° 1.152 that aims to align national rules with those practiced by the Organization for Economic Cooperation and Development (OECD)

On this past Wednesday, June 14, 2023, Law N° 14.956/2023 was sanctioned, which modifies the transfer pricing rules used in international transactions between related companies. The objective of the law is to align national standards with the Arm's Length principle, according to the standard recommended by the OECD.

The new transfer pricing rules come into effect from January 2024, but taxpayers can choose to apply them in advance from January 2023.

The option must be formalized during the period from September 1 to September 30 of this year, through the opening of a digital process via the e-CAC portal. Below, we highlight the main changes brought about by the new legislation:

Although the text of the Law brings the necessary changes, it is still necessary to await the publication by the Federal Revenue with the specific regulations for the practical applicability of the changes.