Stephanie Makin

One of the relevant topics is the tax treatment of contingent considerations and any other type of price adjustments and their effects on the tax amortisation of goodwill.

Provisional Measure (MP) 1152, published on December 29, 2022, substantially amended the Brazilian transfer pricing rules currently in force for transactions carried out between related parties, with the purpose of aligning them with the OECD Guidelines.

April 2022 saw the Brazilian Federal Revenue Service and the OECD present a proposal for the new Brazilian TP system