BEPS Brazil Profile

July 2016


1) Has Brazil implemented any BEPS recommendations? If so, which Action Items?
Formally, Brazil is not implementing any BEPS recommendations.  Although Action 12 was adopted through a Provisional Measure, it was not implemented into Law; thus, the Measure is no longer in effect.

2) What is Brazil’s expected timeline for implementing country-by-country reporting?
Brazil does not follow the OECD Guidelines for transfer pricing.

3) Are Brazilian taxing authorities taking any measures to prepare for any changes brought about by BEPS (e.g., changes in staffing, increases in budgets)?
As far as we know, there will not be a substantial change due to BEPS in Brazil.