Nélio Weiss Philippe Jeffrey As widely known, Brazil's transfer pricing rules do not adopt the internationally accepted arm's-length standard. For instance, for the purposes of applying the Brazilian equivalent to the resale price method (PRL) in transactions involving import of goods between related parties abroad, regulations provide the use of statutory fixed margins to derive a benchmark ceiling price. In these instances, actual transfer pricing practiced by the local tested party must be lower than that derived benchmark price, otherwise tax authorities will impose a transfer pricing adjustment.
November 01 2011