Transfer pricing

Transfer Pricing

Legislation


Laws

10451/02Changes the Federal Tax Legislation and establishes other provisions.

9430/96Provides for Federal Tax Legislation, contributions for Social Security administrative process of consult and establishes other provisions.

9959/00Changes the Federal Tax Legislation and establishes other provisions.

11196/05Article 36. The Minister of Finance is hereby authorized to institute, for a certain period, a transfer pricing adjustment mechanism in relation to the provisions set forth in the main section of article 19 of Law no. 9430 of December 27, 1996.

11281/06Article 11. Import operations performed by an importing company that purchases goods abroad for resale to a predetermined orderer shall not be construed as imports to the account and at the request of third parties.

12715/12Amends Law no. 9430 of December 27, 1996, and provides for other matters.

12766/12Amends Law no. 9430 of December 27, 1996, and provides for other matters.


Regulatory Instructions

1037/10Lists countries or jurisdictions with favored taxation and privileged tax regimes.

243/02Provides for the prices to be adopted in operations relating to purchase and sale of goods, services and rights carried out between individuals or legal entities resident or domiciled in Brazil and individuals or legal entities resident or domiciled abroad deemed to be related parties.

321/03Changes the Regulatory Instruction n° 243, 2002, which provides for transfer pricing.

382/03Changes the SRF Regulatory Instruction n° 243/2002 which provides for transfer pricing.

602/05Treats the disposition, for the calendar-year of 2005, of adjustments to prove the adequacy of transfer prices in export transactions in order to reduce the impacts related to Brazilian currency exchange rate valuation compared with other currencies.

703/06Treats the disposition, for the calendar-year of 2006, of adjustments to prove the adequacy of transfer prices in export transactions in order to reduce the impacts related to Brazilian currency exchange rate valuation compared with other currencies.

801/07Treats the disposition, for the calendar-year of 2007, of adjustments to prove the adequacy of transfer prices in export transactions in order to reduce the impacts related to Brazilian currency exchange rate valuation compared with other currencies.

898/08Treats the disposition, for the calendar-year of 2008, of adjustments to prove the adequacy of transfer prices in export transactions in order to reduce the impacts related to Brazilian currency exchange rate valuation compared with other currencies.

1010/10Treats the disposition, for the calendar-year of 2009, of adjustments to prove the adequacy of transfer prices in export transactions in order to reduce the impacts related to Brazilian currency exchange rate valuation compared with other currencies.

1124/11Treats the disposition, for the calendar-year of 2010, of adjustments to prove the adequacy of transfer prices in export transactions in order to reduce the impacts related to Brazilian currency exchange rate valuation compared with other currencies.

1233/12Treats the disposition, for the calendar-year of 2011, of adjustments to prove the adequacy of transfer prices in export transactions in order to reduce the impacts related to Brazilian currency exchange rate valuation compared with other currencies.

1312/12Provides for the prices to be adopted in purchase and sale operations involving goods, services or rights carried out by individuals or legal entities resident or domiciled in Brazil with individuals or legal entities resident or domiciled abroad, deemed related parties.


ORDINANCE

222/08Regulates the percentages and profit margins to be applied on prices to be used as parameter on transactions of purchase and sale of goods, services and rights, carried out by entities resident or domiciled in Brazil, with related entities domiciled abroad.

4/11Establishes, for calendar year 2010, adjustment mechanisms to determine transfer prices on exports, in order to reduce the impacts related to the appreciation of the national currency as compared to other currencies.

563/11Establishes, for calendar year 2011, adjustment mechanisms to determine transfer prices on exports, in order to reduce the impacts related to the appreciation of the national currency as compared to other currencies.


Rationales

9430/96Disclosure of Rationales (EM) for Law no. 9430/96, Providing for the Transfer Price Rules.


RIR

3000/99(Corporate Income Tax New Regulation, Decree n° 3.000 of March 26, 1999,Published in the Federal Official Gazette (DOU) of March 29, 1999.


Declaratory Act

37/02Disqualification of technical research pursuant to art. 21 of Law No. 9430, 1996.

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