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Brazil transfer pricing documentation guide

March 22, 2008

TP Week correspondent Machado Associados outlines the environment for transfer pricing documentation in Brazil

Brazilian transfer pricing rules determine that prices charged on transactions with related parties shall be compared with those resulting from the application of the methods described in the law in order to verify whether such prices are based on the fair market price. If the actual price adopted differs from the market price, the difference will be added to the taxable basis of income tax and social contribution on net profits. However, these rules do not expressly provide an official list of documents and information to be used for such calculations.

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