Transfer pricing rules for sales of equity stakes
April 03, 2009
It has been discussed whether Brazilian transfer pricing rules apply to the sale of shares and quotas held by Brazilian companies to a related party, as defined by law (including residents in low tax jurisdictions and beneficiaries of privileged tax regimes).
According to law 9430/96, transfer pricing rules apply to imports and exports of goods, services and rights and to payments of interest to and from Brazil in transactions between related parties.
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