Ahead of Its Time by Being Late? The Correlation between the Atypical Brazilian Transfer Pricing Rules and Amount B of the OECD Pillar One Proposal

This article provides an analysis of the usually neglected Amount B of Pillar One in light of similar safe harbour rules that have already been implemented in the legislation of developing countries. The author highlights how the OECD and the Inclusive Framework are expected to seize this opportunity for harmonization and simplification by building on existing experiences in the international arena.