The Federal Revenue Service presents new Normative Instructions on Transfer Pricing and opens Public Consultation. The deadline for suggestions and comments is September 30, 2024

On August 28th, the Special Secretariat of the Federal Revenue Service (“SRFB”) presented the first drafts of the Normative Instructions (“INs”) that will regulate the new Brazilian Transfer Pricing Law (No. 14.596/2023), more specifically transactions with intra-group services (Annex I of the Consultation) and the Unilateral Advance Pricing Agreement (APA), concluded under the Specific Consultation Process (Annex II of the Consultation). In addition to presenting the INs drafts, the SRFB has opened a Public Consultation process for interested parties to offer their comments.

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The statement of reasons of the Public Consultation states that interested parties will be able to offer comments and suggestions on the INs drafts, as well as on the provisions already contained in Normative Instruction No. 2161/2023, which is responsible for the general regulation of the new transfer pricing rules.

In the latter case, interested parties can also describe any difficulties or doubts in applying Normative Instruction 2.161/2023 and send suggestions for points that could be clarified by means of examples.

Submissions should be sent between August 29, 2024, and September 30, 2024, to cotin.df.cosit@rfb.gov.br, preferably in pdf format.

Any requests to schedule meetings should be sent to subgab.rfb@rfb.gov.br.

Access the free translation to English of the Public Consultation here.