Brazilian taxpayers need to comply with new OECD-based transfer pricing rules as of financial years starting on or after 1 January 2024. They are also allowed to apply the new rules for financial years starting on or after 1 January 2023, if they choose for “early adoption” later this calendar year. This article outlines the practical impact of the new rules for Brazilian taxpayers, based on its underlying concepts and a case study including intra-group transactions that Brazilian taxpayers are commonly engaged in. In addition, the authors aim to illustrate some key considerations, opportunities, and risks of the upcoming decision whether to adopt early.