123ArticleOnline Logo
Welcome to 123ArticleOnline.com!
ALL >> Business >> View Article

Amendments To The Transfer Pricing Methods In Brazil- What You Need To Know

Profile Picture
By Author: Alice Coope
Total Articles: 213
Comment this article
Facebook ShareTwitter ShareGoogle+ ShareTwitter Share

The recent developments in Brazil’s transfer pricing policies and the use of fixed profit margins are an attempt to simplify the administration of transfer pricing methods, thereby reducing the number of tax audits. The Brazilian government introduced changes to transfer pricing rules which include a range of fixed profit margins for various industry sectors. Although the main changes are effective January 1, 2013, the rules can also be applicable for calendar year 2012.

Details of Provisional Measure 563

New fixed profit margins for the purpose of calculation of the Resale Minus Profit method (Preço de Revenda menos Lucro – PRL). While the existing profit margins are 20% for transactions related to import of goods for resale and 60% for transactions related to imported raw materials for use in manufacturing processes, the new profit margins will range between 20%, 30% or 40% depending on the economic activity of the legal entity.

A profit margin of 40% has been allotted for legal entities involved in the manufacture of pharma products, tobacco-based products, optical products, photographic and ...
... cinematographic equipment. It also includes sale of dental products, petrol and natural gas extraction and the manufacture of petrol-derived products.

A profit margin of 30% has been fixed for legal entities involved in the manufacture of chemical products, glass or glass-based products, cellulose, paper or paper-related products and metallurgy.

A 20% profit margin will be applicable for legal entities engaged in any other economic activity in Brazil. The new measure also introduced a reworked methodology to calculate the reference price using PRL method which greatly differs from the existing methodology.

PCI (Price Valuation under Import Transactions - Preço sob Cotação na Importação) and PCEX (Price Valuation under Export Transactions -Preço sob Cotação na Exportação)

As per the PCI and PCEX methods, the average daily stock market valuation of the goods and rights of a particular transaction will be taken into account while comparing the prices used by Brazilian parties with related parties.

New rules for tax deduction of interest payments

New rules related to the taxes on interest payments for loan agreements between a Brazilian entity and a foreign based related party have been introduced. As such, interest payments will now be deductible for tax purpose covering an amount consistent with the London Interbank Offered Rate (LIBOR) for US deposits of 6 months, added to a rate which will be announced by the Ministry of Finance.

Since Brazil does not comply with the OECD transfer pricing policies, the risk of international double taxation is very high. However, of late the Brazilian tax authorities are more open to discussing changes to transfer pricing policies with the representatives of taxpayers. Provisional Measure 563 has also been projected as Brazil’s first move towards adopting OECD’s Arm’s Length Principle.
Even though the Brazilian market is catching attention of investors across the world, it is always imperative to ensure that reliable legal, financial and fiscal advice is taken at the earliest stages of your expansion plan. A professional business consultant having the expertise to reduce risk and liabilities of an overseas expansion can be a safe haven. Giving you assistance in almost all areas of your business like HR legal, international accounting, saas compliance, they allow you to concentrate of your core business activities.

Know more on : tax for expats, eu vat & global transfer pricing

Total Views: 315Word Count: 554See All articles From Author

Add Comment

Business Articles

1. Olmesartan Medoxomil Manufacturers In India
Author: verdanty

2. Usautopartscar - The Best Auto Parts Online & Aftermarket Car Parts Near Me
Author: USAutopartsCar

3. Top-class Ksa India Straw Reaper 756 Xh For Effortless Cutting And Cleaning Of Crop Straw
Author: KS Agrotech

4. Best Oem Panel Registration Consultant Services
Author: Bidz Professional

5. The Top Construction Company In Bihar - Bhushan Realtors Pvt. Ltd
Author: Bhushan Realtors

6. Essential Tips Builders Should Consider Before Hiring An Agent To Sell Property
Author: Horizon Consultants

7. Jamnagar: India’s Hub For High-quality Brass Components
Author: Atlas Metal

8. Top 5 B2b Healthcare Marketing Strategies You Can’t Ignore
Author: Medstreamdata

9. How Does Detectable Caution Tape Improve Workplace Safety?
Author: Nitin Jordan

10. What Are Common Mistakes In Iso 22000 Audit Checklists And How Can They Be Avoided?
Author: Emma

11. How Does One Go About Applying For A Short Term Loans Online?
Author: Robert Miller

12. Transform Your Home With The Best Modular Kitchen Designers In Bangalore
Author: catherin

13. Sap Jaipur - Your Gateway To Efficient Business Management
Author: Akansha

14. 100% Foreign Ownership In Saudi Arabia: A Gateway For Global Investors
Author: adarshhlg

15. Lactobacillus Rhamnosus Manufacturer In Usa
Author: vakya lifescience

Login To Account
Login Email:
Password:
Forgot Password?
New User?
Sign Up Newsletter
Email Address: