Double tax treaties and transfer pricing in Brazil
June 04, 2008
Cristiane Magalhães and Fabíola Costa Girão, of TP Week correspondent Machado Associados, analyse the impact of double tax treaties on transfer pricing policy in Brazil
The terms of international tax treaties take precedence over any domestic tax legislation. Article 98 of Law 5172/66 - the National Tax Code – says that international conventions prevail over and must be observed by the supervening domestic legislation. This article has not been superceded by the Brazilian 1988 Constitution, but this is a controversial issue not yet settled by the Brazilian case law.
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