Transfer pricing

OECD and Brazil launch project to examine differences in cross-border tax rules


28/02/2018 - The OECD and Brazil today launched a joint project to examine the similarities and gaps between the Brazilian and OECD approaches to valuing cross-border transactions between associated firms for tax purposes. The project will also assess the potential for Brazil to move closer to the OECD’s transfer pricing rules, which are a critical benchmark for OECD member countries and followed by countries around the world.


The 15-month work programme will analyse the legal and administrative framework behind the Brazilian transfer pricing system, as well as its implementation.  It will examine strengths and weaknesses in the Brazilian approach while exploring options for greater alignment with the OECD’s internationally accepted standard, the OECD Transfer Pricing Guidelines, which would be an important element of any future process of accession to the Organisation.


“Brazil is a key partner of the OECD, so we are glad to take this step together toward bridging the gaps in transfer pricing,” said OECD Secretary-General Angel Gurría, launching the project with Finance Minister Henrique Meirelles, Federal Revenue Secretary Jorge Antonio Rachid and National Confederation of Industry (CNI) President Robson Braga de Andrade.


“Effective transfer pricing rules arecritical for avoiding double taxation and ensuring that taxable profits are not artificially shifted away. The project we are launching today will enable us to better understand the options for improving the application of transfer pricing rules in Brazil, and achieving greater convergence. This will help enhance the investment climate in Brazil by reducing the risk of double taxation,” Mr Gurría said. (Read the speech in full)


The OECD has long been at the forefront of efforts to develop common approaches to transfer pricing. Building on the 1979 report, Transfer Pricing and Multinational Enterprises, the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations – produced in 1995 and updated in 2017 to incorporate the results of OECD work to counter Base Erosion and Profit Shifting (BEPS) – are followed by countries worldwide. They reflect a common understanding of how to apply the arm’s length principle, which is embedded in both the OECD Model Tax Convention and the UN Model Tax Convention.


As a G20 member, Brazil has worked closely with the OECD on international tax policy issues for many years, and is a member of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes and the Inclusive Framework on BEPS.


Media queries should be directed to Grace Perez-Navarro, Deputy Director of the OECD Centre for Tax Policy and Administration (CTPA), or to Catherine Bremer in the OECD Media Office.


Note to Editors:


The Paris-based OECD is an international organisation that promotes policies to improve the economic and social well-being of people worldwide. It provides a forum in which governments can work together to share experiences and seek solutions to the economic, social and governance challenges they face.


The OECD’s 35 members are: Austria, Australia, Belgium, Canada, Chile, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea, Latvia, Luxembourg, Mexico, the Netherlands, New Zealand, Norway, Poland, Portugal, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Turkey, the United Kingdom and the United States.


Three other countries – Colombia, Costa Rica and Lithuania – were formally invited to start accession discussions and are currently in the process of accession to the Organisation.


Brazil is one of the OECD’s five Key Partners, with China, India, Indonesia and South Africa. Key Partners contribute to the OECD’s work in a sustained and comprehensive manner. A central element of the Key Partners programme is the promotion of direct and active participation in the work of the substantive bodies of the Organisation. This includes partnerships in OECD Bodies, adherence to OECD instruments and integration into OECD statistical reporting and information systems. Further information on OECD cooperation with Brazil:


In May 2017, Brazil submitted a formal letter to the OECD, expressing its interest in initiating an accession process to the Organisation. The OECD governing body, the Council, is currently considering this request, together with similar requests from Argentina, Bulgaria, Croatia, Peru and Romania.


Further information on the OECD accession process:


Working with over 100 countries, the OECD is a global policy forum that promotes policies to improve the economic and social well-being of people around the world.



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