Non-conversion of executive measure into law causes problems in Brazil
June 30, 2010
Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados Advogados e Consultores explain what the failure of MP 478 to become firm law will mean for taxpayers in Brazil.
Since December 2009, Brazilian taxpayers have witnessed several changes in transfer pricing rules. Some were challengeable from a legal perspective, especially the new regulation set out by executive measure 478/09 (MP 478), which should not increase taxation before being constitutionally allowed to. In case the new rules were more beneficial, they could be applied immediately. For more details on the executive measures, see Executive measures change Brazilian transfer pricing rules.
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