Brazil’s Ministry of the Economy reaffirmed on April 12 its commitment to ‘fully converge’ its transfer pricing (TP) rules to the arm’s-length standard (ALS), bringing the rules in line with the OECD TP Guidelines. Specific draft legislation has not yet been released. This announcement is of increased significance to taxpayers in light of the recently adopted final regulations (TD 9959) (the ‘Final Regulations’) by the US Department of Treasury (Treasury) and Internal Revenue Service (IRS) addressing various aspects of the US foreign tax credit (FTC) regime, as well as BEPS 2.0 developments.
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