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Brazil Amends Transfer Pricing Rules for Controlled Commodity Transactions

|Approved Changes|Brazil
Brazil

Brazil has published Normative Instruction No. 2.246 of 30 December 2024, which contains amendments to Normative Instruction RFB No. 2.161 of 28 September 2023, which established the regulations for the country's transfer pricing regime. This includes a new paragraph 8 under Article 37 of Normative Instruction RFB No. 2.161, which provides that for contracts used for recurrent or long-term deliveries, taxpayers must assess, for the purposes of complying with the arm's length principle, wheth…

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