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On September 29, 2023, Brazil’s Federal Revenue (Receita Federal do Brasil or RFB) issued Normative Instruction Nº 2,161 (IN 2,161/23). This instruction confirms the application of transfer pricing (TP) rules to transactions involving related parties abroad, entities in tax havens, and privileged tax regimes.
In accordance with Law 14,596, the OECD’s “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022” will be used as a secondary reference for applying local TP rules. However, this application will only be valid if the guidelines are approved by the RFB and do not contradict existing local laws or regulations.
This documentation is available to download here:
- BR TP Normative Instructions – Word (Portuguese)
This document contains the full text of Brazil’s Transfer Pricing Normative Instruction, outlining rules and guidelines for the new transfer pricing system in Portuguese. File size: 156.02 KB - BR TP Normative Instructions – English Translation (Word)
An unofficial English translation of the Brazilian Transfer Pricing Normative Instruction, detailing the latest transfer pricing regulations as of 2023 for English-speaking users. File size: 109.12 KB - BR TP Normative Instructions – Portuguese (PDF)
The official PDF version of the Brazilian Transfer Pricing Normative Instruction, published in Portuguese, providing legal information and updates on the country’s transfer pricing system. File size: 16.94 MB
