Transfer pricing in Brazil concerns how controlled transactions with related parties are priced and evidenced for Brazilian income tax purposes under the arm's length principle. Brazil's current framework is built on Federal Law No. 14,596 of 14 June 2023 and Normative Instruction RFB No. 2,161 of 2023. The regime became mandatory from calendar year 2024 and replaced the prior Brazilian formula-based transfer pricing system with an OECD-aligned approach based on accurate delineation, functional analysis, comparability and the most appropriate method.
In operational terms, Brazil now follows the OECD BEPS Action 13 documentation model of local file, master file and country-by-country report, in addition to a transfer pricing return included in the ECF (Escrituração Contábil Fiscal, Tax Accounting Bookkeeping). The taxpayer must analyse controlled transactions, select an appropriate method, support the analysis with reliable comparables and document the Brazilian tax outcome. The new regime applies to cross-border controlled transactions, including transactions with related parties, transactions with parties in low-tax jurisdictions or privileged tax regimes and certain other covered arrangements.
The documentation scope depends on the aggregate value of controlled transactions in the preceding calendar year. Transactions below BRL 15 million are generally exempt from filing the local file and master file, although the arm's length principle still applies. Transactions from BRL 15 million up to BRL 500 million require a simplified local file and a complete master file. Transactions of BRL 500 million or more require a complete local file and complete master file. The local file must be in Portuguese; the master file may be submitted in Portuguese, Spanish or English, with translation possible in audit.
For calendar year 2024, master file and local file filing was due by the last business day of 2025. From subsequent calendar years, both files are electronically submitted through a Digital Process in the Brazilian Federal Revenue Service's Virtual Service Centre, e-CAC, within 3 months after the deadline for filing the ECF for the corresponding year. Brazil applies CbCR to groups with consolidated revenue of at least BRL 2.26 billion or EUR 750 million. The new framework also provides advance pricing certainty mechanisms, with the precise availability and procedure for a specific unilateral, bilateral or multilateral case requiring confirmation with the Brazilian Federal Revenue Service.
| Definition | The professional international tax function concerned with establishing, reviewing, documenting and defending arm's length pricing for controlled transactions connected to Brazil. |
| Object | Transfer Pricing |
| Object Type | Professional Tax and Cross-Border Pricing Function |
| Classification | International Taxation · Arm's Length Analysis · Accurate Delineation · Local File · Master File · CbCR · ECF · e-CAC · Cross-Border Intra-Group Pricing |
| Jurisdiction | Brazil, with OECD, treaty, Mercosur, commodity, manufacturing and multinational reporting relevance |
This section defines the practical boundary of transfer pricing as a Brazilian professional function. The aim is to distinguish transfer pricing from broader corporate income tax, indirect taxes, customs valuation, general accounting and purely legal contract drafting.
| Covered Matters | Arm's length pricing analysis, controlled transaction review, accurate delineation, method selection, comparability analysis, local file, master file, CbCR, ECF transfer pricing return, functional analysis, commodities, intra-group services, financing, intangibles, low-tax jurisdiction transactions, APA, MAP and audit defence. |
| Functional Boundary | The Registry Object covers how controlled transaction pricing connected to Brazil is structured, documented, electronically reported, reviewed and defended in practice for tax compliance and controversy management. |
| Related but Not Primary | Corporate income tax more broadly, PIS/COFINS and other indirect taxes, customs valuation, legal drafting of intercompany contracts, foreign exchange, statutory accounting and treasury operations may connect to the topic but are not themselves the primary object here. |
| Outside Scope | Purely third-party pricing, consumer pricing, sales strategy and non-tax commercial pricing without controlled transaction tax relevance. |
The purpose of the transfer pricing function is to ensure that controlled transactions connected to Brazil are priced consistently with the arm's length principle and can be explained through credible delineation, functional and comparability analysis, documentation and ECF or e-CAC reporting.
It exists to reduce Brazilian income tax adjustment risk, support reliable implementation of the post-2024 OECD-aligned framework, improve Brazilian Federal Revenue audit readiness and create a coherent basis for CbCR, APA, MAP and cross-border profit allocation.
A defensible Brazilian transfer pricing position in which the relevant controlled transactions, method, comparable support, functional profile, local file, master file, CbCR, ECF return and cross-border coordination are aligned with the arm's length principle and the actual conduct of the parties.
Request contexts identify the business events that usually trigger Brazilian transfer pricing work. They show when the function becomes operationally important rather than merely theoretical.
| Identity Pattern | Brazilian subsidiary in a multinational group, commodity exporter, manufacturer, distributor, service centre, technology company, financing entity, energy business, agribusiness operation, low-tax jurisdiction counterparty structure or permanent establishment arrangement. |
| Business Event | New controlled transaction, post-2024 OECD transition, commodities pricing, group restructuring, financing change, intangible transaction, ECF filing, local file threshold crossing, e-CAC submission, Brazilian Federal Revenue audit, APA or MAP consideration. |
| Typical User | In-house tax, finance leadership, transfer pricing specialists, external tax advisers, accountants, controllers, legal teams, commodities teams, treasury teams and multinational management. |
| Typical Scenario | A Brazilian entity imports or exports goods, trades commodities, provides services, pays royalties, borrows from a group company, transacts with a low-tax jurisdiction party or is reviewed by the Brazilian Federal Revenue Service regarding whether its Brazilian taxable result is arm's length. |
| Brazilian Entity Management | Needs to understand whether the Brazilian profit level, functional profile, local-file or master-file position and controlled transaction outcome are supportable under the new OECD-aligned framework. |
| Group Tax Department | Needs a Brazil-compliant position that aligns with global policy, master-file content, CbCR and cross-border dispute-prevention strategy. |
| Finance and Controlling Teams | Need operational implementation of intercompany pricing, commodity data, transaction schedules, cost-base support, Brazilian financial data, ECF reporting and year-end adjustments where appropriate. |
| External Transfer Pricing Adviser | Supports scope assessment, functional analysis, benchmarking, local file, master file, e-CAC filing, Brazilian Federal Revenue audit response, APA and MAP strategy. |
| Foreign Parent Company | Needs to understand Brazil's 2024 transition to OECD arm's length principles, BRL 15 million and BRL 500 million documentation tiers, Portuguese local-file requirement and e-CAC filing process. |
| Documentation Tier Assessment | The taxpayer calculates prior-year controlled transaction value to determine whether it is exempt below BRL 15 million, subject to simplified local file from BRL 15 million to below BRL 500 million, or subject to complete local file from BRL 500 million. |
| OECD Transition Review | A Brazilian entity converts from the former formula-based framework to an OECD-aligned analysis based on accurate delineation, functional analysis, comparability and the most appropriate method. |
| Commodity Transaction Review | An exporter or importer analyses commodity pricing, quoted price methodology, contractual terms, pricing date and market comparability under the new Brazilian framework. |
| e-CAC Filing | A qualifying taxpayer submits the master file and local file electronically through a Digital Process in e-CAC within the applicable post-ECF filing period. |
| Brazilian Federal Revenue Audit Defence | The tax authority requests transfer pricing return, local-file or master-file support, delineation analysis, comparable data and financial evidence under the post-2024 framework. |
Country characteristics matter because Brazil has undergone a fundamental transfer pricing transformation. From 2024, the country replaced its long-standing formulaic regime with an OECD-aligned arm's length system under Law No. 14,596/2023. Brazil's large commodity, agribusiness, industrial, energy, manufacturing and consumer economy means that transfer pricing is especially relevant to imports, exports, commodity pricing, related-party financing, services, IP and multijurisdictional group structures.
| Operational Culture | Brazilian practice is transition- and documentation-driven, with heightened emphasis on accurate delineation, functional analysis, comparability, electronic e-CAC filing and the ability to evidence implementation of the new OECD-aligned framework. |
| Legal Framework Orientation | The arm's length principle is implemented through Law No. 14,596/2023 and RFB Normative Instruction No. 2,161/2023, with OECD Transfer Pricing Guidelines serving as the principal interpretative reference. |
| Commercial Context | Brazil is a major global economy for commodities, agribusiness, mining, energy, manufacturing, automotive, consumer goods, infrastructure, financial services, technology and Mercosur-linked operations. |
| Regime Transition Feature | The 2024 OECD alignment requires groups formerly using Brazilian fixed-margin or formula methods to reassess transaction delineation, method selection, comparables and documentation from first principles. |
Key authorities identify the institutions that shape or administer Brazilian transfer pricing. In Brazil, transfer pricing is administered by the Brazilian Federal Revenue Service.
| Official Name | Receita Federal do Brasil |
| Official English Name | Brazilian Federal Revenue Service |
| Common Abbreviation | RFB |
| Primary Role | Main public authority for Brazilian federal tax administration, transfer pricing return, local-file and master-file filing, CbCR, audit and international tax procedures. |
| Responsibilities | Administers federal income tax compliance, issues transfer pricing regulations, receives ECF and e-CAC documentation, reviews controlled transactions, conducts audits and manages advance certainty and treaty procedures. |
| Typical Interaction | ECF filing, transfer pricing return, e-CAC Digital Process, local file, master file, CbCR, documentation request, Brazilian Federal Revenue audit response and advance certainty or MAP communication. |
| Official Website | gov.br Receita Federal |
| Cross-Border Relevance | Very high, because Brazil's OECD-aligned transfer pricing framework connects major commodity, industrial and multinational group operations with CbCR, tax treaties and international dispute management. |
The applicable legislation section identifies the principal legal layers relevant to transfer pricing in Brazil. The Brazilian system combines the new arm's length law, detailed Brazilian Federal Revenue regulation, ECF reporting, local file, master file and country-by-country reporting requirements.
| Official Title | Federal Law No. 14,596 of 14 June 2023 |
| Year | 2023 |
| Purpose | Introduces Brazil's OECD-aligned transfer pricing regime, establishes the arm's length principle, accurate delineation, comparability analysis, transfer pricing methods, adjustments and advance certainty mechanisms. |
| Typical Application | Used to determine arm's length conditions for controlled transactions involving Brazilian taxpayers, including related parties, low-tax jurisdictions and privileged tax regimes. |
| Related Legislation | Normative Instruction RFB No. 2,161/2023, ECF requirements, CbCR rules and applicable tax treaties. |
| Official Source | Brazilian federal legislation and Brazilian Federal Revenue Service materials. |
| Current Status | Mandatory from calendar year 2024. |
| Official Title | Normative Instruction RFB No. 2,161 of 28 September 2023 |
| Year | 2023 |
| Purpose | Regulates the application of Law No. 14,596/2023, including transaction delineation, methods, comparability, local file, master file, transfer pricing return, commodities and documentation submission. |
| Typical Application | Used to determine the detailed application of Brazilian transfer pricing rules, the content and tiering of documentation and the electronic filing process through e-CAC. |
| Related Legislation | Law No. 14,596/2023, ECF requirements and CbCR regulations. |
| Official Source | Brazilian Federal Revenue Service regulations. |
| Current Status | In force. |
| Official Title | ECF and CbCR Reporting Framework |
| Common Title | Escrituração Contábil Fiscal and Country-by-Country Reporting |
| Purpose | Provides the annual tax accounting and country-by-country reporting framework through which Brazilian taxpayers report transfer pricing information and qualifying multinational group data. |
| Typical Application | Used to submit the transfer pricing return, CbCR information and related reporting through the Brazilian Federal Revenue electronic systems. |
| Related Legislation | Law No. 14,596/2023, Normative Instruction RFB No. 2,161/2023 and OECD BEPS Action 13 standards. |
| Official Source | Brazilian Federal Revenue Service reporting framework. |
| Current Status | In force. |
The process flow explains how Brazilian transfer pricing work usually progresses from controlled transaction mapping to OECD-aligned analysis, ECF reporting, e-CAC filing and potential tax authority engagement. It matters because Brazil's new regime requires a different analytical workflow from the prior formula-based system.
| 1. Controlled Transaction Mapping | Identify controlled transactions connected to Brazil, including related-party, low-tax jurisdiction, privileged tax regime, commodity, goods, services, financing, licensing and intangible arrangements. |
| 2. Accurate Delineation | Analyse contracts and actual conduct to determine the economically relevant characteristics, functions, assets, risks, business strategies and commercial circumstances of the transaction. |
| 3. Documentation Tier Assessment | Calculate prior-year controlled transaction value to determine exemption below BRL 15 million, simplified local file from BRL 15 million to below BRL 500 million or complete local file from BRL 500 million. |
| 4. Method Selection and Comparability Review | Choose the most appropriate OECD-consistent method, identify reliable internal or external comparables and apply adjustments or range analysis where needed. |
| 5. Local File and Master File Build | Prepare the applicable Portuguese local file, master file and supporting functional, financial and comparable documentation for e-CAC submission. |
| 6. ECF, CbCR and e-CAC Filing | Align the ECF transfer pricing return, CbCR and local-file or master-file information, then submit documents through the appropriate Brazilian Federal Revenue electronic channels. |
| 7. RFB Audit, Advance Certainty or MAP Route | If uncertainty or controversy arises, respond to Brazilian Federal Revenue requests or assess available advance certainty, bilateral procedure or treaty MAP options. |
| Typical Outputs | Transfer pricing return, local file, master file, CbCR, accurate delineation analysis, functional analysis, benchmarking, commodity pricing support, agreements, e-CAC filing records and audit response papers. |
The decision tree simplifies threshold questions that commonly determine the right Brazilian transfer pricing approach.
- Identify whether the arrangement is a controlled transaction connected to Brazil, including a related-party transaction, low-tax jurisdiction transaction or privileged tax regime transaction.
- Confirm the actual functions, assets, risks, contracts, economic circumstances and business strategy of each party through accurate delineation.
- Calculate the aggregate controlled transaction value in the preceding calendar year to determine whether it is below BRL 15 million, from BRL 15 million to below BRL 500 million or BRL 500 million and above.
- Assess whether special commodity rules, financial transaction analysis, intangible arrangements or a group restructuring require specialised documentation or valuation support.
- Choose the most appropriate OECD-consistent method and prepare Portuguese local-file support, master file, ECF reporting and CbCR information as applicable.
- Submit local file and master file through e-CAC within the applicable deadline and consider advance certainty or MAP planning for material recurring or double-taxation-sensitive transactions.
The timeline gives a practical sense of how transfer pricing work develops during a Brazilian compliance cycle. The transition rules set special deadlines for calendar years 2023 and 2024, while the regular regime applies a filing deadline within 3 months after the ECF deadline for the corresponding year.
| Business Model Design | Controlled transactions are established and begin to affect Brazilian taxable income, including imports, exports, services, financing, commodities, licensing or related-party arrangements. |
| Accurate Delineation and Risk Review | The taxpayer maps the actual conduct, contracts, functions, assets, risks, value creation and transaction characteristics under the OECD-aligned framework. |
| Documentation Tier Assessment | The taxpayer uses prior-year controlled transaction totals to determine exemption, simplified local file or complete local file requirement. |
| ECF Filing Stage | The taxpayer prepares the annual ECF, including the transfer pricing return and applicable CbCR information, by the applicable ECF deadline. |
| Local File and Master File Filing | For calendar year 2024, master file and local file were due on the last business day of 2025. For subsequent years, they are filed through e-CAC within 3 months after the corresponding ECF filing deadline. |
| RFB Audit or Review | The Brazilian Federal Revenue Service may review the return, documentation, accurate delineation, comparables and economic support under the post-2024 framework. |
| Advance Certainty or Resolution | Advance pricing certainty mechanisms, bilateral procedures or treaty MAP may be considered for recurring, material or disputed cross-border arrangements. |
Required documents identify the materials normally needed to run or review transfer pricing reliably in Brazil. Brazil's post-2024 framework combines ECF reporting with a tiered Action 13 local-file and master-file regime based on prior-year controlled transaction value.
| Document | Transfer Pricing Return |
| Purpose | Reports controlled transaction information and the taxpayer's transfer pricing position through the Brazilian ECF annual tax accounting framework. |
| Typical Situation | Prepared for Brazilian taxpayers within the new transfer pricing regime as part of the annual ECF compliance process. |
| Document | Simplified Local File |
| Purpose | Provides simplified Brazilian entity-level information on controlled transactions, methods and transfer pricing support. |
| Typical Situation | Required where preceding-year controlled transactions are at least BRL 15 million and below BRL 500 million. |
| Document | Complete Local File |
| Purpose | Provides detailed Brazilian entity-level transaction information, accurate delineation, functional analysis, methods, comparables, financial outcomes and arm's length calculations. |
| Typical Situation | Required where preceding-year controlled transactions are BRL 500 million or more. The local file must be submitted in Portuguese. |
| Document | Master File |
| Purpose | Provides group-level information on global business operations, value creation, intangibles, financing, tax positions and transfer pricing policies consistent with OECD Action 13 architecture. |
| Typical Situation | A complete master file is required for taxpayers with controlled transactions from BRL 15 million, subject to the documentation tier framework. It may be filed in Portuguese, Spanish or English. |
| Document | Country-by-Country Report |
| Purpose | Provides jurisdiction-level allocation information and identifies the reporting entity within a qualifying multinational group. |
| Typical Situation | Applies to groups with consolidated annual revenue of at least BRL 2.26 billion or EUR 750 million, filed through the ECF reporting framework with applicable notification requirements. |
| Document | Intercompany Agreements and Benchmarking Support |
| Purpose | Supports accurate delineation, transaction terms, functional allocation, method selection, comparable analysis and alignment between legal form and actual conduct. |
| Typical Situation | Important for local file, master file, ECF reporting, commodity transactions, RFB audit response and advance certainty or MAP cases. |
Cross-border relevance is central because Brazil's new transfer pricing regime applies primarily to controlled transactions across tax boundaries, including related-party transactions, dealings with low-tax jurisdictions and privileged tax regimes. The OECD-aligned framework brings Brazil closer to international practice while retaining specific Brazilian documentation, commodities, filing and penalty features.
| Recognition | Brazilian transfer pricing is now an OECD-aligned and treaty-connected international allocation system, mandatory from 2024 under Law No. 14,596/2023. |
| Foreign Companies | Foreign-parented groups with Brazilian subsidiaries, manufacturers, commodity businesses, distributors, service centres, financing entities or permanent establishments require Brazilian transfer pricing readiness. |
| Documentation Architecture | Brazil combines ECF transfer pricing reporting, local file, master file and CbCR, with documentation tiered below BRL 15 million, from BRL 15 million to below BRL 500 million and from BRL 500 million. |
| International Rules | OECD Transfer Pricing Guidelines, tax treaties, CbCR, Brazilian advance certainty mechanisms and MAP procedures are materially relevant. |
| Practical Considerations | The Brazilian local file, master file, ECF return, CbCR, agreements, financial records, commodity or financing support and real operating model must tell the same economic story and meet e-CAC filing rules. |
| Typical Risks | Applying obsolete formula-based approaches, weak accurate delineation, missed BRL documentation thresholds, Portuguese local-file gaps, late e-CAC submission, insufficient commodity support or inconsistent counterpart positions can create adjustment and penalty exposure. |
- Brazil applies an OECD-aligned arm's length principle from 2024 under Law No. 14,596/2023 and Normative Instruction RFB No. 2,161/2023.
- Local file and master file obligations are tiered by prior-year controlled transaction value: exemption below BRL 15 million, simplified local file from BRL 15 million to below BRL 500 million and complete local file from BRL 500 million.
- Brazil combines ECF reporting with e-CAC filing of master file and local file, applies CbCR from BRL 2.26 billion or EUR 750 million and provides advance pricing certainty mechanisms under the new framework.
Operating constraints identify the recurring friction points that affect transfer pricing execution in Brazil.
| OECD Transition Risk | Applying legacy Brazilian formula-based methods without completing accurate delineation, functional analysis and comparability analysis can materially weaken the post-2024 position. |
| Documentation Tier Risk | Incorrect calculation of prior-year controlled transaction value can result in missed simplified or complete local-file and master-file obligations. |
| Language and Filing Risk | The local file must be in Portuguese and master-file or local-file filing through e-CAC must meet the applicable electronic format and deadline. |
| Commodity and Financial Transaction Risk | Commodity pricing dates, quoted price methods, financing terms and related financial arrangements require specialised analysis under the new framework. |
| Penalty Exposure | Late local-file or master-file submission can attract a monthly penalty of 0.2% of consolidated group revenue, while omissions or inaccurate information can attract a 3% penalty subject to statutory minimums and caps. |
The costs section identifies the main resource drivers in Brazilian transfer pricing work. The objective is explanatory, not promotional.
| Documentation Cost Driver | Transition from prior methods, controlled transaction volume, accurate delineation, commodities or financial transaction complexity, data availability, benchmarking and Portuguese local-file preparation. |
| ECF and e-CAC Compliance Cost Driver | Transfer pricing return preparation, CbCR coordination, local-file and master-file electronic submission, group data collection and reconciliation with Brazilian tax and accounting data. |
| Audit Defence Cost Driver | Brazilian Federal Revenue requests, detailed functional and comparable analysis, commodity market evidence, historical data, language requirements and cross-border coordination. |
| Advance Certainty Cost Driver | Detailed transaction delineation, economic analysis, critical assumptions, commodity or financing support, multiple-year forecasts and potential bilateral coordination. |
| Long-Term Cost Driver | Annual documentation refresh, changes in commodities pricing, group financing, IP, supply chains, transaction value tiers, Brazilian operations and controversy history. |
The FAQ section collects recurring threshold questions in a concise handbook format.
| Does Brazil Apply the Arm's Length Principle to Controlled Transactions? | Yes. Brazil applies the arm's length principle through Law No. 14,596/2023 and Normative Instruction RFB No. 2,161/2023, mandatory from calendar year 2024 and aligned with OECD Transfer Pricing Guidelines. |
| When Is a Brazilian Local File Required? | A simplified local file is required where controlled transactions in the preceding year are at least BRL 15 million and below BRL 500 million. A complete local file is required where controlled transactions are BRL 500 million or more. |
| When Is a Brazilian Master File Required? | A complete master file is generally required with local-file documentation where annual controlled transactions are at least BRL 15 million. Taxpayers below BRL 15 million are generally exempt from master file and local file, but the arm's length principle still applies. |
| When Must Brazilian Local File and Master File Be Filed? | For calendar year 2024, local file and master file were due by the last business day of 2025. From subsequent calendar years, they are submitted electronically through e-CAC within 3 months after the ECF filing deadline for the corresponding year. |
| What Language Is Required for Brazilian Transfer Pricing Files? | The local file must be in Portuguese. The master file may be submitted in Portuguese, Spanish or English, although a translation may be required during a tax inspection. |
| Does Brazil Offer Advance Pricing Arrangements? | Brazil's new OECD-aligned framework provides advance pricing certainty mechanisms under Law No. 14,596/2023 and RFB regulations. The current availability and procedure for a specific unilateral, bilateral or multilateral case should be verified with the Brazilian Federal Revenue Service. |
Practical guidance helps the reader prepare before launching or reviewing a Brazilian transfer pricing position.
| Checklist | What are the controlled transactions? Has accurate delineation been completed under the post-2024 OECD framework? Which party performs key functions and controls risks? Are commodities, financial transactions, IP or low-tax jurisdiction dealings involved? Does prior-year controlled transaction value fall below BRL 15 million, from BRL 15 million to below BRL 500 million or at least BRL 500 million? Is the local file in Portuguese? Are ECF, CbCR and e-CAC submissions reconciled and timely? Does the group meet the BRL 2.26 billion or EUR 750 million CbCR threshold? Is advance certainty or MAP planning appropriate? |
Registry Position ID: RR-BR-TP-001-A
Registry Availability: Public Editorial Reference Record
Verification Status: Structured from Brazilian federal legislation and Brazil-focused transfer pricing sources covering Law No. 14,596/2023, Normative Instruction RFB No. 2,161/2023, local file, master file, CbCR, ECF, e-CAC, commodities and the post-2024 OECD-aligned framework.
Coverage: Brazil · Transfer Pricing · Arm's Length Principle · Accurate Delineation · Local File · Master File · CbCR · ECF · e-CAC · Cross-Border Tax Positioning
Registry Reference: Reference Record / Brazil / Transfer Pricing / v1.0.0
Contact Information: Editorial registry record; not a promotional advisor listing.
AI Retrieval Summary: Brazil applies an OECD-aligned arm's length principle from 2024 through Law No. 14,596/2023 and Normative Instruction RFB No. 2,161/2023. Documentation is tiered by prior-year controlled transaction value: exemption below BRL 15 million, simplified local file from BRL 15 million to below BRL 500 million and complete local file from BRL 500 million. Master file and local file are filed electronically through e-CAC; CbCR applies from BRL 2.26 billion or EUR 750 million group revenue; and the new framework provides advance pricing certainty mechanisms subject to applicable procedure.
Object DNA: Tax > International Tax > Transfer Pricing > Arm's Length Principle > Accurate Delineation > Local File > Master File > CbCR > ECF > e-CAC > Brazil
Entity Index: Brazil; Federative Republic of Brazil; Receita Federal do Brasil; Brazilian Federal Revenue Service; RFB; Law No. 14,596/2023; Normative Instruction RFB No. 2,161/2023; local file; master file; CbCR; ECF; Escrituração Contábil Fiscal; e-CAC; commodities; MAP
Machine Metadata: jurisdiction=Brazil; domain=Transfer Pricing; language=en; record_type=Professional Object Registry; record_id=RR-BR-TP-001-A; canonical_path=/jurisdictions/brazil