Brazil amends transfer pricing rules: New rules for deductibility of intercompany interest and new normative instruction [TAX ALERT]

January 22, 2013

On 28 December 2012 the Law 12.766/12 introduced further changes to the recently enacted changes to the Brazilian transfer pricing rules for interest paid to related parties.

Also, Normative Instruction (IN) 1.312/12 was published the same day to consolidate Brazil’s transfer pricing legislation and revoked all previous Normative Instructions related to transfer pricing, mainly IN 243/02.

In addition, IN 1.312/12 provides guidance on the application of Law 12.715/12. As we commented in our previous Tax Alert (20 September 2012), the intention of Law 12.715/12 is to simplify compliance, reduce areas of controversy and attract more investment.

Further details are available from the Ernst & Young Tax Alert which can be accessed using the link below:

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