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Difficulties when applying the Brazilian comparable independent price (CIP)

August 15, 2011

Sophie Ashley - TPW

Brazil’s transfer pricing rules are predominantly outlined in Law 9430, as amended, and by the Federal Revenue Service’s Normative Instruction (NI) 243.

As per the Brazilian legislation, the taxpayer is allowed to choose one of three transfer pricing methods: comparable independent prices (CIP); resale price less profit; and production cost plus profit, to calculate the benchmark prices in the import of assets, goods, services or rights.

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