A Brazilian entity can earn BRL 500 million and have only BRL 5 million in controlled transactions; another can earn BRL 40 million and import BRL 20 million from its parent. The second falls into the documentation band while the first may not. Start with controlled-transaction value, not the entity’s commercial size.
BRL 15 million measures transactions, not revenue
| Company | Revenue | Controlled transactions | Documentation result |
|---|---|---|---|
| Aurora Co. | BRL 500m | BRL 5m | Below the Local and Master File filing band |
| Boreal Co. | BRL 40m | BRL 20m | Simplified Local File + Master File |
The examples are illustrative. The actual calculation must confirm which transactions fall within the regime, the relevant period and the values before adjustments.
What the BRL 15m–100m band normally triggers
The simplified Local File covers the six article 61 items. The Master File follows article 58. CbCR depends on consolidated group revenue and the ultimate parent jurisdiction.
Scope follows the transactions, not a page count
| Scope driver | Why it changes the work |
|---|---|
| Number and type of transactions | Goods, services, royalties, intangibles and finance require different facts and methods |
| Reliable internal comparables | May provide stronger evidence and reduce reliance on external databases |
| Segmented financial data | Determines whether results and adjustments can be tied to the tested transaction |
| Contract versus conduct | A mismatch requires delineation based on actual facts and evidence |
| HQ coordination | Controls access to the Master File, global policy and approvals |
Brazilian law sets no universal page or comparable count. A defensible scope states assumptions, sources, exclusions, dependencies and acceptance criteria.
Who needs to participate inside the business
| Owner | Contribution |
|---|---|
| Brazil Tax | Band, method, ECF and filing process |
| Accounting/Controllership | Ledger, segmentation, reconciliations and adjustments |
| Legal/Procurement | Contracts, amendments and actual workflow |
| Operations/Commercial | Functions, assets, risks and conduct |
| Global Tax/HQ | Master File, group policy, global data and approval |
The tax manager may sponsor the technical work, but the file depends on facts owned by several functions. Assign an owner and due date to each evidence request.
Compare vendors by scope, not by an unqualified fee
| Procurement question | Verifiable answer |
|---|---|
| Which transactions are included? | List by type, counterparty and period |
| Is a comparable search included? | Method, database, criteria, access and deliverables |
| Who interviews the functions? | RACI across company, advisor and HQ |
| Who localises the Master File? | Article 58 matrix and owner of each gap |
| Is filing support included? | Process, file limits, receipts and amendments |
| What is the acceptance test? | Reconciliations, sources, version and documented approval |
Without this matrix, fees are not comparable. Project cost depends on the scope and source-data condition; a universal market price would be misleading.
Build the deadline and risk into the plan
Article 66 separates late filing, a non-compliant file, Master File inaccuracies and failure to cooperate with an audit. Each fine has a BRL 20,000 floor and BRL 5 million ceiling; article 65 also permits estimates and allocation of functions, assets and risks where information is missing.
References and official sources
Define the scope before comparing proposals
TaxUp maps the transactions, assigns data owners and turns the filing obligation into a scope with deliverables and acceptance criteria.
Request a scope reviewFrequently asked questions
Does a company with BRL 30 million in revenue need a Local File?
How much does a Brazil Transfer Pricing project cost?
How many pages and comparables are required?
Is the Master File also required in this band?
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