NEW TRANSFER PRICING LAW
(TAX team from TATICCA Curitiba - partners Marcio Costa and Luiz Carlos Benner)
On June 15, 2023, Law 14.596 was published on the conversion of Provisional Measure (MP) 1.152/22, which deals with Transfer Pricing. One more step towards the announced changes.
In general, the Law remained the same as the provisional measure that originated it. The most notable exception was the suppression of an article, number 19, which dealt with secondary adjustment and the interest that would be incurred thereon. The secondary adjustment itself disappeared from article 17. The law established that adoption for 2023 is optional and for 2024 it is mandatory (option must be made by September/2023 - according to IN 2132 of February/2023). A normative instruction necessary to clarify what the practical procedures will be has not yet been published.
The movement that can already be noticed in conversations with specialists, is that multinational companies in general, adopt the new rules only in 2024, waiting for a consolidation of the new rules.
To access the new law in its entirety, on the official website:
https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/lei/l14596.htm
Need help with your Transfer Pricing? Count on TATICCA Allinial Global Brasil's TAX team.
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