Brazil has published Normative Instruction No. 1870 of 29 January 2019, which amends regulations for various aspects of Brazil's transfer pricing regime provided under Normative Instruction No. 1312/2012. One of the main aspects is the timing for the calculation of benchmark prices when using certain transfer pricing methods. This includes:
In relation to the timing of benchmark prices, it is provided that for interest on net equity (JCP), where the PIC, CPL, or PCI methods are used, the adjustment impact on net equity will be in the year in which the import transaction took place, and where the PRL method is used, the adjustment impact will be in the year of consumption.
Other aspects include:
Normative Instruction No. 1870 entered into force on 30 January 2019.