Brazil: Transfer pricing – layout changes in the ECF

published on 12 March 2024 | reading time approx. 1 minute

The new Transfer Pricing guidelines have changed the tax system related to transfer pricing, including tax obligations for the 2024 tax year.

Previously, the ECF layout was simpler from a transfer pricing point of view and did not require extensive detailing of intercompany transactions.

In this new scenario, the layout has undergone significant changes, since all taxpayers involved in controlled transactions are subject to filling in the new records for Transfer Pricing on the ECF, even those in the Safe Harbour – companies with total values of up to 15 million in controlled transactions.

The update to the ECF's Readout 10 points out mandatory entries such as the type of controlled transaction, identification of the related parties, the value of the controlled transaction, the value of the spontaneous or compensatory adjustment and the method used. This information is presented in the following ECF records: X360, X365, X366, X370, X371, X375A, X375B, X375C, X375D and X375E.

The deadline for submitting the Tax Accounting Bookkeeping (ECF) is 31 July 2024.