A recent decision on importation from the Brazilian administrative courts reopened a transfer pricing question that appeared to be definitively settled in favour of the Brazilian Federal Revenue (RFB). Gil Mendes, and Daniel Perin, of Ernst & Young analyse how a taxpayer became the first to prevail over the authorities on the issue.
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ITR spoke to two US TP experts about the long-running dispute, with one arguing that the case highlights ‘weaknesses’ with the comparable uncontrolled transaction method
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