Brazil

Corporate taxation

The corporate tax rate in Brazil is 34%, composed of IRPJ at the rate of 25 % and CSLL at the rate of 9%.

Transfer pricing

Up until 2022 Brazil’s transfer pricing rules defined maximum price ceilings for deductible expenses on inter-company import transactions and minimum gross income floors for inter-company export transactions. There were no direct reference to the arm’s length principle in the rules.

In December 2022 draft legislation was issued to align Brazil’s transfer pricing system with the OECD Transfer Pricing Guidelines which introduces the arm’s length principle – methods, comparability standards and documentation requirements.

For FY 2023 Brazilian taxpayers can choose between the old and the new transfer pricing rules, but for FY 2024 the new OECD-based rules will be mandatory.

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