Brazil's MAP tax dispute mechanism to gain relevance with 2025 BEPS adherence

Brazil's Mutual Agreement Procedure (MAP), regulated by RFB Normative Instruction No. 1,846/2018, is expected to become more relevant as the country adheres to the Multilateral Convention of the BEPS in 2025. This development signals a shift toward international tax dispute resolution, potentially affecting cross-border tax certainty for investors. The impact is contingent on implementation details and treaty partner cooperation.