Normative Instruction RFB 2.161/2023

The Federal Revenue Office of Brazil has published the highly anticipated RFB Normative Instruction No. 2,161/2023, which regulates the new transfer pricing rules introduced by Law No. 14.596/2023. The main aspects addressed by this Normative Instruction include the application of the Organisation for Economic Co-operation and Development (“OECD”) transfer pricing guidelines, a broader view of the global transactions carried out by economic groups, the definition of related parties, the delineation of controlled transactions, comparability analysis, simplification measures, ancillary obligations, among others.

Demarest’s Tax team is available to provide any further clarifications that may be necessary.”