A Disciplina dos Preços de Transferência no Brasil

uma Avaliação

Abstract

Brazil has passed a law regulating transfer pricing 12 years ago approxi-mately. Now it has come the time to reevaluate the procedures then adopted to check if they are in line with international regulations about the same subject. One can observe that decisions made according to Brazilian Federal Revenue are not in accordance with the arm’s length principle once the concern the establishment of a market price, but with the strict application of the existing law besides this, Brazil resorts to fixed profit margins in determining the methods that establisher a reference price, without taking into consideration the market profit margins, characteristic of different segments. The efficacy of such approach should be examined carefully.