Are pre-sales agreements with the tax authorities possible in your area of expertise? If so, what form do they usually take (e.g. B unilaterally, bilaterally or multilaterally) and which companies and transactions can they cover? Brazilian transfer pricing rules apply to transactions between a Brazilian party and a foreign-related company or a company established in a tax haven country or subject to a privileged tax regime. As a general rule, Brazilian transfer pricing rules follow the principles of subcontracting, but deviate significantly from the OECD guidelines, as they provide only for certain methods and fixed legal margins. The legislation allows the taxable person to freely choose the method, since no rules of the best method and no functional analysis are necessary. Taxpayers who wish to continue to benefit from insurance on their tax treatment can request prior tax confirmation under the new procedure. It is remarkable that, while this can generally only be used for transactions that have not yet been completed, so a new transfer pricing agreement and agreement may be required, the bill appears to allow for new advance tax returns for these old and existing transactions. . . .