What is Transfer Pricing and who must comply with Law 14,596/2023?

It is the set of rules that determines how transactions between related parties must be priced for IRPJ and CSLL purposes. Since January 1, 2024, the new regime, aligned with the OECD arm's length principle, is mandatory for every legal entity domiciled in Brazil with controlled transactions abroad.

Which companies must file the Local File and the Master File?

It depends on the volume of controlled transactions in the previous year: below BRL 15 million, filing the documentation is waived, but the rules remain fully applicable (the company must still practice arm's length prices and make adjustments when needed); between BRL 15 million and BRL 500 million, the simplified Local File applies; above BRL 500 million, the full one. The Master File follows the requirements of IN RFB 2,161/2023.

What are the risks of non-compliance?

Article 35 of Law 14,596/2023 provides for penalties of 0.2% per calendar month on gross revenue for late filing, 3% on gross revenue for filing without meeting the requirements, and 5% on the transaction value in cases of inaccurate or omitted information about the multinational group and of documents not presented during a tax procedure. Minimum of BRL 20 thousand and maximum of BRL 5 million per infraction, in addition to exposure to assessments, adjustments and double taxation.

My headquarters already prepares the global documentation. Does that cover Brazil?

Not automatically. The global documentation must be checked against the Brazilian requirements, which have their own minimum content. Reviewing Master Files prepared abroad is one of our most frequent services for multinational groups.

I only buy from independent suppliers abroad. Am I outside the regime?

Not necessarily. Transactions with residents of low-tax jurisdictions or beneficiaries of privileged tax regimes fall under the transfer pricing rules even when the counterparty is fully independent, with no corporate relationship. It is the scenario that most often surprises companies under inspection.

Is it possible to structure a Transfer Pricing policy from scratch?

Yes. We serve both companies starting intercompany operations and consolidated groups that need to adapt their global policy to the Brazilian rules.

It is Apter's Operational Transfer Pricing platform, within the TP360 ecosystem: the margins of controlled transactions are monitored month by month against the market range, with adjustment simulation before closing and an auditable trail, with Apter Copilot, our AI layer, supporting the analysis.

APTER TP360Transfer Pricing

Exclusive dedication to Transfer Pricing. The structure of a 360º consultancy.

From transaction delineation to continuous monitoring: Transfer Pricing studies, documentation and management under Law 14,596/2023 and IN RFB 2,161/2023, for multinational groups in Brazil and abroad.

Law 14,596/2023OECD GuidelinesMaster & Local File

Talk to a specialist See the solutions

BENCHMARKING · COMPARABLESARM'S LENGTH

Database: TP Catalyst · Bureau van DijkStandard: OECD · Law 14,596/2023

Apter TP360 · the complete Transfer Pricing ecosystem

Apter SmartFlowproprietary method

Apter OTPplatform · continuous monitoring with AI

Apter Academyeducation and training

APTER TP360 · OUR SOLUTIONS

Complete solutions, tailored to each client

Each solution below is delivered within the Apter TP360 ecosystem: a proprietary method, a monitoring platform with embedded artificial intelligence and an education practice, working together. From the initial diagnosis to continuous monitoring, the scope is sized and designed according to the operations, complexity and needs of each company.

How we deliver

Every solution runs on Apter SmartFlow

Apter SmartFlow is Apter's proprietary methodology, built on the arm's length principle and aligned with the OECD at every stage. In the complete Transfer Pricing study it unfolds into the 3 phases and 7 steps below, from kick-off to the filing of ancillary obligations. In the other solutions, we apply the steps relevant to the engaged scope, with the same technical rigor.

Apter SmartFlow

the Apter Transfer Pricing method · 3 phases and 7 steps, applied in full to the complete study

PHASE 01Transaction Delineation

PHASE 02Comparability Analysis

PHASE 03Formalization of Calculations

Tap each step to see what happens in it.

OECD alignment at every phaseReal data and quantitative analysisDocumentation auditable and traceableExecutive report for management, auditors and headquarters

Apter OTP

Operational Transfer Pricing

More than compliance. A management tool.

Apter OTP turns Transfer Pricing into decision support: margins monitored throughout the year make it possible to adjust prices and anticipate results, instead of merely documenting the past.

This kind of follow-up is already standard practice with our clients: the interim calculation, with a formal report on a base date agreed with management, anticipates IRPJ and CSLL adjustments before the annual closing. Apter OTP brings this practice into the platform and turns interim into continuous.

Operational data comes in via upload, RPA, API or ERP connector and feeds the recurring monitoring of the profitability indicators of each controlled transaction.

Margins (PLI) tracked month by month against the market range
Adjustment simulation before the fiscal year closes
Auditable trail from raw data to the reported number

The AI layer of TP360

Apter Copilot

Specialist artificial intelligence reading the OTP numbers, flagging deviations and pointing out adjustment opportunities. Every analysis is validated by the consultant in charge before reaching the client.

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Apter OTP · margin monitorfiscal year 2026 · YTD

Apter Copilot: the manufacturing margin is approaching the 1st quartile. Adjustment simulation suggested before the Q3 close.

Benchmarking with TP Catalyst (Bureau van Dijk · Moody's), the world reference database of comparables for Transfer Pricing studies.

OUR DELIVERY MODEL

Technology should not become the client's workload. That is why we do not sell software: we deliver its result.

SaaS

Sells the tool

The software belongs to the client, and so do the operation, the configuration and the interpretation of the numbers.

Apter · SaaSw

Delivers the result

The software runs behind the scenes and the consultant is up front. The client receives the number ready and defensible.

APTER ACADEMY · EDUCATION

Transfer Pricing can also be taught

Training and workshops for companies: the new law in practice, documentation, intercompany operations and regulatory updates. Teams that understand the rules make fewer mistakes in day-to-day operations and reduce the company compliance risk.

I want to train my team

In company

A program designed around your company's operations

Workshops

Specific topics: the new law, documentation, methods, JTF and deadlines

Companies that structured their Transfer Pricing with Apter

Who leads this practice

A team exclusively dedicated to Transfer Pricing within the Tax practice, supported by all the other Apter practices.

Anderson Nishiura

Managing Partner

More than 16 years in audit and tax consulting in direct taxes for national and multinational companies. Specialist in Transfer Pricing and speaker at training sessions and workshops. Manager at PricewaterhouseCoopers for more than 10 years.

Ronival Silva

Director · Tax | Transfer Pricing

Leads Apter's Transfer Pricing practice: studies under Law 14,596/2023, international benchmarking, and documentation for multinational groups. Over 15 years of experience in audit and consulting, including more than 8 years as a manager at PricewaterhouseCoopers, serving multinational companies across various industries, with a strong foundation in IFRS and US GAAP.

Larissa Rocha

Director · Tax | Transfer Pricing

More than 16 years of experience in transfer pricing and foreign trade, including 14 years at Deloitte as Global Trade Advisory Senior Manager. Leads compliance projects in transfer pricing and cross-border indirect taxation for multinational and domestic groups across various segments, with a solid foundation in special customs regimes and tax and customs risk management.

Transfer Pricing is the only agenda of this team. That guarantees close tracking of regulatory changes, always up-to-date benchmarking and consistent technical responses throughout the relationship. And whenever the subject touches accounting, data or corporate matters, the other Apter practices join the project without handing the baton to third parties.

Boutique dedication. The structure of a 360º consultancy.

Within Apter's Tax practice there is a team that does one single thing: Transfer Pricing. Specialists exclusively dedicated to intercompany pricing, benchmarking and documentation under Law 14,596/2023.

The difference is what surrounds that team. When the subject touches accounting, the Audit team is in the next room. When it requires automation and data, the Digital practice joins the project. When it crosses corporate or payroll matters, Advisory and Outsourcing respond without intermediaries.

Specialization and structure should not be a trade-off. At Apter, the client gets both at the same time: exclusive dedication to Transfer Pricing, inside a full-service consultancy, with partners and directors leading from start to finish.

Exclusive TP team

A specialty, not a side task of the tax practice.

Seniors on the front line

Directors leading the project from start to finish.

Five integrated practices

Tax, Digital, Advisory, Audit and Outsourcing under one roof.

Proprietary technology

Apter OTP, Apter Copilot and Apter Academy within the TP360 ecosystem.

THE STRUCTURE BEHIND IT · APTER IN NUMBERS

500+

active clients across all practices

60%

are multinationals

200+

professionals

offices, 2 outside Brazil

Brazil

Sorocaba

Iguatemi Business

Brazil

Sorocaba

CIESP

Brazil

Barueri

Alphaville

Paraguay

Asunción

Support for regional operations

United States

Miami

Support for international operations

Go deeper into the subject

Permanent technical content and recurring analyses from the Transfer Pricing team.

The complete technical guide to the new regime, free of charge

Who is in scope, related parties and the favored-jurisdiction trap
The methods, the delineation and the interquartile range
Obligations, deadlines, penalties and the 10-point attention checklist

Material updated through 07/31/2026 · signed by the Apter Transfer Pricing team

Exclusive dedication to Transfer Pricing. The structure of a 360º consultancy.