Brazilian court clarifies use of resale minus method
March 09, 2011
The Brazilian Taxpayer’s Council, responsible for analysing federal tax appeals, and the Brazilian Federal Regional Court have issued decisions, favouring the Brazilian Revenue Service (BRS), over the resale minus method (RMM) for calculating a transfer pricing adjustment.
Brazilian law defines the RMM as the average resale price of goods or services, with the exclusion of unconditional discounts granted, taxes and contributions levied on sales, commissions and brokerage fees paid and the 20% profit margin calculated on the resale price.
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