Transfer pricing

Transfer Pricing

Resolution 13

The Resolution nº 13 of 2012, from the Brazilian Senate, established that all interstate operations of imported goods would have a tax rate of 4% for Tax on the Circulation of Goods, Interstate and Intercity Transportation and Communication Services (“ICMS” Brazilian acronyms). In addition, the Resolution 13 informs the situations when the applicability of the tax rates is not valid, being those goods which, after the customs clearance, were not applied in none industrialization process and even those who did suffered any value addition resulting in a product with more than 40% of imported content, with the exception of the goods that does not have any Brazilian similar.

The New Transfer Pricing Solutions - Resolution (New TPS Resolução) – software developed by the Brazilian Deloitte professionals calculates the percentage imported contained in the goods and also defines the tax status of the product while leaving the company, all accordantly to the Resolution nº 13 of 2012 of the Brazilian Senate, beyond that, the client will have support of our experienced professionals for consulting and advisory.


  • Monthly calculation;
  • Traceability of the information which compose the calculation of the imported content;
  • Generation of the Imported Content Form (FCI), which contains the information demanded by the legislation in order to determinate the participation of the imported parcel in the whole product, in addition, it identifies the taxpayer and the product;
  • Integration with SAP, and others.

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