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10. Brazil

Brazil

Monetary threshold for LF preparation

​ Applicable if the total amount of cross-border related-party transactions (before transfer pricing adjustments) is:

  • Over BRL 500 million: Full Local File

  • Between BRL 15 million and BRL 500 million: Simplified Local File

  • Less than BRL 15 million: No documentation required (but an explanation must be provided upon request)

Preparation deadline

  • By the due date for filing the company’s corporate income tax return.

Submission deadline

  • Within 3 months of the deadline for filing the corporate income tax return via the e-CAC system.

Language

  • Portuguese

Penalty

  • A penalty of 0.2% of the taxpayer’s gross income per month (or part thereof) may be imposed for failure to submit the LF.

  • Failure to meet the LF requirements may result in an additional penalty of 3% of gross income for the relevant period.

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