ABSTRACT
In light of the recent approximation between Brazil and the OECD, the article discusses the main challenges and advantages of the Brazilian TP legislation. The authors propose a dual system for the Brazilian transfer pricing regime, which is a feasible alternative to bring Brazil closer to the OECD Guidelines.
SCHOUERI, L. E.; GALENDI JUNIOR, R. A. . Brazil – Challenges to Brazilian Transfer Pricing Rules upon Accession to the OECD. International Transfer Pricing Journal, v. 26, p. 1-19, 2019