Freight, insurance and import duties: How taxpayer triumphed against authorities
October 12, 2011
A recent decision on importation from the Brazilian administrative courts reopened a transfer pricing question that appeared to be definitively settled in favour of the Brazilian Federal Revenue (RFB). Gil Mendes, and Daniel Perin, of Ernst & Young analyse how a taxpayer became the first to prevail over the authorities on the issue.
The Superior Chamber of Federal Appeals (SCFA) has ruled in favour of a Brazilian taxpayer in the case of whether the importation cost should include charges with freight, insurance and non-recoverable importation taxes, in the application of the resale price method (RPM).
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