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Brazil’s transfer pricing rules v OECD’s guidelines

August 17, 2010

Tatiana Villani and Anna Cecília Brasil of Machado Associados comment on the main differences between Brazil’s transfer pricing rules and the OECD’s guidelines, and the difficulties and opportunities that this may create for taxpayers.

Although Brazil’s transfer pricing rules are, to some extent, inspired by the OECD guidelines, some particularities can be easily pointed out, such as: (i) the adoption of a broader concept of related parties; (ii) the existence of different methods for import and export transactions, which make limited use of the arm’s-length principle; (iii) the adoption of fixed profit margins in the case of the resale price and cost plus methods.

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