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New decision on transfer pricing “may become important precedent” in Brazil

December 13, 2010

Cristiane M. S. Magalhães and Iara M. S. Sousa do Amaral of Machado Associados explains why a decision of the Federal Regional Court of Appeals of the 3rd region (TRF) may become an important precedent for transfer pricing in Brazil.

The panel of the TRF decided, by majority vote, that Normative Instruction No 243/02 (NI243) of the Federal Revenue Service (FRS) had overstepped its regulatory competence when it established how to calculate the 60% profit margin, under the Resale Price Less Profit (PRL 60) method. As a result, it granted the taxpayer the right to calculate the PRL 60 method based on the provisions of Law No 9430/96, disregarding the regulations of NI 243.

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