In 2022, new treaties were signed with Colombia, Norway, Poland and the United Kingdom in line with the Action 14 Minimum Standard. Furthermore, amending protocols were signed with China, Chile and India implementing the Action 14 Minimum Standard in those treaties.
Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023
OECD/G20 Base Erosion and Profit Shifting Project
Brazil
Recent developments relating to MAP in Brazil prior to 15 August 2023
Developments relating to MAP in the tax treaty network
Other developments relating to MAP
No developments were reported
Latest Action 14 Peer Review report
18 October 2021 - https://doi.org/10.1787/30e8a050-en
Tax treaty network of Brazil
39 treaties, applicable to 40 jurisdictions (covering all treaties signed, although not necessarily in force)
status of MLI: not signed.
Table 1. State of play of Brazil's tax treaty network
Source: OECD
Brazil's MAP programme
Organisation of competent authority function
nine persons:
two heads of unit
seven persons working on MAP cases (all of which work on other tasks as well).
contact persons for MAP requests:
Special Secretary of Federal Revenue of Brazil (competent authority of Brazil)
Point of contact: International Relations Office (Asain)
Address: Setor de Autarquias Sul, Quadra 3, Bloco “O”, Sala 805 CEP: 70.079-900 – Brasília/DF
Email asain@rfb.gov.br.
Figure 1. Competent Authority Organisational Structure
Source: OECD
Table 2. Guidance on the MAP process
Overview of Brazil's MAP Statistics for 2022
Please refer to https://www.oecd.org/tax/dispute/map-statistics-brazil.pdf for details with respect to Brazil's MAP Statistics.
Figure 2. Cases closed in 2022
Source: OECD
Figure 3. Evolution of Brazil's MAP caseload (2016-22)
Source: OECD
Table 3. Overview of Brazil’s MAP caseload for 2022
Source: OECD
Table 4. Brazil’s average time to resolve MAP cases in 2022
Source: OECD