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How to survive a transfer pricing audit in Brazil

April 03, 2008

TP Week correspondent Machado Associados reports on the process for transfer pricing audits in Brazil

Brazilian transfer pricing rules intend to avoid the artificial allocation of profits between different jurisdictions by means of manipulating import and export prices of goods, services or rights and interest charges. Transfer pricing control in Brazil solely affects the calculation of the Corporate Income Tax (IRPJ) and the Social Contribution on Net Profit (CSLL) and such rules were introduced by Law no 9430/97, which aims at restraining:

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