Brazil: IRS publishes Normative Ruling to regulate the new Transfer Pricing rules

On September 29, the Brazilian IRS (“SRFB”) published Normative Ruling RFB nº 2,161/2023 (“IN 2,161/23”), in order to regulate the new transfer pricing system introduced in Brazil through Law nº 14,596/2023.

One of the main points of attention is the postponement – until December 31st – of the deadline to opt for the early adoption of the new rules in 2023.