The Brazilian Senate is reportedly considering a deferral of the country's new transfer pricing regime. As previously reported, the new regime was introduced through a provisional measure and will enter into force on 1 January 2024, although taxpayers may elect to apply the transfer pricing rules from 1 January 2023, which is an irreversible election. Given that the regime was introduced through a provisions measure, it must be further approved by the National Congress.
The Chamber of Deputies (lower house) approved the regime on 30 March 2023 with certain amendments ( previous coverage). The regime must now be approved by the Senate, which is considering a deferral of the entry into force date until 1 January 2025, although taxpayers could still elect to apply the transfer pricing rules from 1 January 2023.