The Brazilian Government on December 29 issued Provisional Measure (MP) 1.152/22 seeking alignment with the arm’s length principle (ALP) in accordance with the OECD Transfer Pricing Guidelines. The MP is effective immediately with the force of federal law. In order to remain effective, Congress must ratify the MP within 60 days from the date of publication (discounting Congressional recess, the initial deadline is April 2023), and convert it into ordinary law. This term may be extended for an additional period of 60 days (i.e., by June 2023). Congressional amendments to the provisions of the MP may be proposed by February 3, 2023.
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