New transfer pricing law

NEW TRANSFER PRICING LAW

(TAX team from TATICCA Curitiba - partners Marcio Costa and Luiz Carlos Benner)

On June 15, 2023, Law 14,596 was published on the conversion of Provisional Measure (MP) 1,152/22, which deals with Transfer Prices. Another step towards the announced changes.

In general, the Law was the same as the provisional measure that originated it. The most notable exception was the deletion of an article, 19, which dealt with secondary adjustment and interest that would be incurred on it. The secondary adjustment itself disappeared from Article 17. The law stated that adoption for 2023 is optional and for 2024 it is mandatory (option must be made by September/2023 - according to IN 2132 of February/2023). A necessary regulatory instruction has not yet been published to clarify what the practical procedures will be like.

The movement that can already be seen in conversations with specialists is that multinational companies, in general, adopt the new rules only in 2024, pending the consolidation of the new regulations.

To access the new Law in full, through the official website:

https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/lei/l14596.htm

Need help with your Transfer Pricing? Count on the TAX team from TATICCA Allinial Global Brazil.

Contact TATICCA — ALLINIAL GLOBAL, which operates throughout Brazil and globally, with integrated auditing, accounting, tax, corporate finance, technology, risk advisory, business consulting and training services. For more information, visit www.taticca.com.br or email taticca@taticca.com.br and learn more. Our company has professionals with extensive experience in the market and has certified methodologies for carrying out activities.

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