Transfer Pricing Brazil: New OECD Rules Hit 2026
Fines up to R$ 5 million if you ignore them
Por Lucas Ribeiro Cavalcante — OAB/CE 44.673
Transfer Pricing Brazil: New OECD Rules Hit 2026
Fines up to R$ 5 million if you ignore them
Por Lucas Ribeiro Cavalcante — OAB/CE 44.673
You import from your parent, pay royalties to a sister company, or lend inside the group. Then you hear Brazil changed everything. Are you still compliant?
✘ Mito
Old Brazil: fixed profit margins, PRL, PIC, CPL formulas
✓ Verdade
New Brazil: OECD arm's length, real market comparison
For decades Brazil applied a formula, not a market analysis. Simple, but it produced results with no link to reality. That isolated system is now gone for good.
2024
The year the new arm's length regime became mandatory. By 2026 the old margins no longer exist
Dica
The change came through Lei nº 14.596/2023, detailed by IN RFB nº 2.161 and 2.162/2023. There is no option to keep the old margins. Pricing the old way exposes you to adjustments.
Local File
Master File
Country-by-Country Report
Who is affected by these rules?
Almost every Brazilian entity transacting with related parties abroad: imports, royalties, loans, fees.
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Prove your intercompany prices match what independent parties would charge, or pay the price.
Do not risk a R$ 5 million fine. Check your compliance before the 2026 deadline closes in.