Brazil has published Normative Instruction 2.132 of 17 February 2023, which establishes the rules for the applications of the country's new transfer pricing regime to controlled transactions carried out in 2023. As previously reported, Provisional Measure No. 1.152 of 28 December 2022 provided for the introduction of a new transfer pricing regime that is in line with OECD standards. The new regime will enter into force on 1 January 2024, although taxpayers may elect to apply the transfer pr…