Brazilian taxpayers and practitioners continue to clamor for more guidance on the country’s new transfer pricing regime implemented last year.
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The country switched from a mathematical model to an arm’s-length principle for transfer pricing last year, bringing it in line with global standards.
That pivot left a lot of questions for the Receita Federal, the country’s revenue authority, to answer through guidance, and it’s been working to issue rules ever since. Most recently, Brazil issued instructions requiring extensive reporting ...