The RFB (Receita Federal do Brasil – Federal Revenue of Brazil) has launched a public consultation to amend RFB Normative Instruction No. 2.161/2023, which regulates the registration of controlled commodity transactions. This measure intends to align Brazilian rules with international guidelines, promoting greater transparency and fairness in international transactions.
Transfer Pricing Significance in Brazil
Transfer Pricing is fundamental to ensure that related-party transactions located in different jurisdictions are at market values to avoid mispricing that could reduce the tax base in Brazil, ensuring fair taxation and avoiding tax evasion.
Details of the Public Consultation
The public consultation, due to the Receita Federal, encourages companies, professionals, and citizens to suggest and comment on the amendments proposed to the RFB Normative Instruction No. 2.161/2023 to improve the regulation of related-party commodity transactions, ensuring compliance with the Arm’s Length Principle.
Participation and Deadlines
Interested parties may contribute until December 11, 2024. The active participation of society is essential to building a regulation reflecting the needs and realities of the Brazilian market, in addition to strengthening legal certainty and confidence in the national tax system.
Next Steps
After the closure of the public consultation, the Receita Federal will analyze the contributions received and, if necessary, adjust the text of the Normative Instruction before its final issuance. The new rules should come into force as of January 2025, providing companies with time to adapt to the new requirements.
Conclusion
Revising the Transfer Pricing rules for commodities in Brazil represents a significant advance in aligning with international standards and strengthening the tax system. The participation of all sectors in this public consultation is crucial to ensure that the regulations are effective and fair.
For further information and details on participating in the public consultation, please see the official website of the Receita Federal do Brasil.
Source: Receita Federal
