Brazil’s Transfer Pricing Rules and Dual VAT: Where Direct and Indirect Taxation Should Not Interact | Tax Notes International

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Tax & Customs

Caio Malpighi, associate from Tax & Customs practice, is the author of an article published by Tax Notes International addressing the impacts of Brazil’s recent tax reform on the interaction between transfer pricing rules and the new dual VAT system (IBS and CBS), in light of Law No. 14,596/2023 and Constitutional Amendment No. 132/2023 and Supplementary Law No. 214/2024.

In the article, Caio examines whether transfer pricing adjustments, primarily linked to IRPJ and CSLL, may affect the taxable base of IBS and CBS, and discusses the challenges arising from the application of market value standards to related-party transactions within the consumption tax framework.

Read the full article here.

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Brazil’s Transfer Pricing Rules and Dual VAT: Where Direct and Indirect Taxation Should Not Interact | Tax Notes International

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