Changes in Transfer Pricing

Changes in Transfer Pricing

Transfer Pricing and the Implementation of the New Model

Text written with contributions from Alison Fernandes, Barbara Mussi, and Fabio Godoy. 
Changes in Transfer Pricing

Transfer pricing, which refers to the rules applicable to transactions between companies within the same economic group, has been undergoing various changes. Since the publication of Law No. 14,596/2023, the Brazilian Federal Revenue Service has sought to address the need to adapt to new economic realities and to seek tax equity through normative instructions such as IN 2161/2023. The objective of applying the new Transfer Pricing model is to increase transparency, prevent tax evasion, and align with global practices.

Current Context

Transfer pricing is necessary for the correct allocation of profits between different tax jurisdictions. The complexity of international operations and the growing digitalization of business challenge traditional norms, requiring constant updates to ensure that the prices practiced reflect economic reality.

Challenges and Considerations

The new Transfer Pricing rules present several challenges for multinational companies and tax authorities:

  • Compliance and Implementation: Companies need to review and possibly redesign their transfer pricing policies to ensure compliance with the new rules. This involves significant effort in terms of documentation and economic analysis.
  • Regulatory Complexity: Harmonizing international rules with local standards can be complex. Companies operating in multiple jurisdictions need to be aware of regional variations and their tax implications.
  • Technology and Automation: The increasing use of technology and automation in transfer pricing analysis can help manage complexity but also requires significant investments in systems and training.


The recent changes in transfer pricing reflect a global commitment to tax equity and transparency. Companies and tax authorities must work together to ensure that transactions between related parties are conducted fairly and in accordance with the new guidelines. Adapting to these changes is essential for the integrity of the international tax system and for promoting a more balanced and sustainable business environment.

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