Rules silent on cost sharing agreements in Brazil
May 24, 2010
Cristiane Magalhães and Henrique Erbolato of Machado Associados Advogados e Consultores in Brazil discuss how the country's complex transfer pricing rules affect cost sharing agreements.
As opposed to the OECD guidelines and the US transfer pricing rules, there is no specific section in the Brazilian transfer pricing legislation (BTPL) dealing with cost sharing agreements. The Brazilian Civil Code also does not have specific rules governing this matter. The silence of the law has contributed to several debates between taxpayers and the tax authorities, especially if the BTPL must be applied to cost sharing agreements.
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