TP documentation.
3 mandatory layers.

Local File — Brazilian entity

A detailed document of the Brazilian company, containing:

• A specific functional analysis (FAR) of each intercompany operation
• A comparability analysis with comparable benchmarks
• The method applied and justification for the choice (CUP, RPM, CPM, TNMM, PSM)
• A quantitative demonstration of adherence to the arm’s length range

Who is required

Every Brazilian legal entity with cross-border intercompany operations above the threshold (generally BRL 15M of intercompany operations in the year).

Filing deadline

Together with the ECF (Tax Accounting Bookkeeping), by the last business day of July of the calendar year following the base year.

The Local File is the document the tax authority analyzes in an audit — it needs to be robust and self-contained. For mid-market companies, see Simplified Local File.

Master File — global view of the group

A global document of the multinational group, with a consolidated view:

• The group’s corporate structure (global org chart)
• The consolidated value chain
• Critical intangibles (brands, patents, know-how)
• Intragroup financial activities (cash pooling, intercompany loans, guarantees)
• The group’s consolidated tax position

A higher-level focus, describing the global strategy and economic allocation across jurisdictions. Generally prepared by the parent company and made available to subsidiaries.

Who is required

Multinational groups with consolidated global revenue > €750 million in at least 2 of the last 4 fiscal years.

Language

It may be in English (the international standard). The Receita Federal accepts a Master File in English with a sworn translation of specific parts if requested.

Country-by-Country Report (CbCR)

A report by jurisdiction with standardized data:

• Revenue (from related and independent parties)
• Profit/loss before taxes
• Covered taxes paid
• Covered taxes accrued
• Stated capital
• Accumulated earnings
• Number of employees
• Tangible assets

Its purpose is risk assessment for tax authorities — it is not binding for a direct adjustment, but it triggers audits in jurisdictions where the data appears inconsistent (e.g., high revenue in a tax haven with no employees, chronic losses in a high-tax jurisdiction, etc.).

Who is required

The same groups as the Master File (> €750M of global revenue). Filed by the ultimate parent entity (UPE) or by a designated entity of the group.

Integration with OECD Pillar 2

The CbCR gains additional relevance under OECD Pillar 2 — the CbCR data is an input for calculating the consolidated ETR by jurisdiction.

Penalties for non-compliance

Failure to comply with the ancillary documentation obligations carries specific fines:

• Failure to file: 0.2% to 3% of revenue (according to the infraction)
• Late filing: 0.02% per day of delay, capped at 1% of revenue
• Inaccuracy or omission of data: BRL 500 to BRL 1,500 per inconsistency

But the greater risk is the tax adjustment: without documentation, the tax authority can arbitrate the applicable method and margin — generally against the taxpayer. The ex officio fine on the adjustment is 75% of the tax, increased to 100% (fraud/collusion) and 150% only in recidivism (Law 9,430/96, am. Law 14,689/2023).