<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 explanation required 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 LF.

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

  • Reference: Normative Instruction Nº 2161 (Portuguese)