Law number 14,596, dated 15th of June, 2023, finally enacted the adoption by Brazil of the arm’s length principle as the driver to identify and assess transfer pricing adjustments to the Corporate Income Tax base, converging to OECD and HMRC practice. The Brazilian Federal Revenue is about to publish a specific advance ruling disclosing its interpretation of the new legal framework, having already initiated a public consultation.
The new transfer pricing regime becomes mandatory as of January 2024, but there is the possibility for taxpayers to choose applying it already this year, retrospectively to January 2023.
In this video, you will hear from Brazilian and British tax practitioners about the main features of the new rules, which points may be perceived as entailing litigation, and practical examples of its implications to cross-border business transactions involving Brazil and the United Kingdom.
Programme:
Opening
- Vera Innes, Chair of the Brazilian Chamber of Commerce in Great Britain
- Gustavo Braga, LLM, founding partner at BBSA – Braga & Bastos Soc. Adv. and Head of the Tax Committee of the Brazilian Chamber of Commerce in Great Britain
The British Perspective
- Kim Allen, BTG Pactual, Head of International Taxes
The Brazilian Perspective
- Marcio Oliveira, EY's partner and Brazil Transfer Pricing leader
- Francisco Lisboa Moreira, partner at ALMA LAW – Aguiar, Lisboa e Monteiro Advogados, LLM in international tax New York University