New transfer pricing decisions in Brazil
February 02, 2011
Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados analyse developments concerning methodology and safe harbours
A recent and unpublished decision by the Administrative Council of Tax Appeals (CARF) is creating controversy in the transfer pricing field. This was the first case where CARF had to decide on the validity of a tax assessment grounded on the rules that Normative Instruction 243 (NI 243) established for the Brazilian Import Resale Minus Method with a 60% profit margin (PRL 60), a method that is applicable when the imported item is used in production.
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