10. Brazil

Monetary threshold for LF preparation
Applicable if the total amount of cross-border related-party transactions (before transfer pricing adjustments) is:
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Over BRL 500 million: Full Local File
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Between BRL 15 million and BRL 500 million: Simplified Local File
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Less than BRL 15 million: No documentation required (but an explanation must be provided upon request)
Preparation deadline
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By the due date for filing the company’s corporate income tax return.
Submission deadline
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Within 3 months of the deadline for filing the corporate income tax return via the e-CAC system.
Language
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Portuguese
Penalty
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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.
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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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Reference: Normative Instruction Nº 2161 (Portuguese)
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