For the US, the most important bilateral trade issue has nothing to do with the Chinese authorities' failure to reduce excess steel capacity, as promised, and stop subsidizing exports. Trump no doubt sees potential political gains in steel- and aluminum-producing districts and in increasing the pressure on Canada and Mexico as his administration renegotiates the North American Free Trade Agreement. The European Union has announced plans to retaliate against US exports, but in the end the EU may negotiate — and agree to reduce current tariffs on US products that exceed US tariffs on European products. But the real target of the steel and aluminum tariffs is China.
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Thiago Medaglia of Felsberg Advogados discusses the unique features of the Brazilian transfer pricing legislation and provides an update of new measures.
If the actual price of a given import is considered not to satisfy transfer pricing rules, a portion of it is considered non-deductible and a positive primary adjustment is made for income tax purposes.
In turn, a minimum taxable revenue should be booked if the actual price of a given export does not satisfy the transfer pricing rules. Nonetheless, it is important to bear in mind that the Brazilian transfer pricing system is absolutely unique, differing enormously from the rules found in the majority of the developed countries and even from the OECD guidelines.
In this sense, Brazilian transfer pricing rules are usually better understood if their differences are explained from the start.
Accordingly, this introductory topic aims at presenting some of the unique features of the Brazilian rules before addressing them in more detail. Another important difference is that Brazil does not adopt what is internationally known as the best method rule.
In Brazil, taxpayers are entitled to freely choose any of the existing methods. Certain scholars even defend that, should a tax inspection on transfer pricing be initiated, tax authorities are required to choose the methodology that offers the best result for the taxpayer the less burdensome methodology.
In Brazil, transfer pricing rules only apply to international transactions.
Transactions entered into with companies located in low tax jurisdictions are immediately subject to transfer pricing rules regardless of the existence of any corporate or business relationship connecting the parties.
The low tax jurisdictions are blacklisted by Normative Instruction No. Rumour has it that a new blacklist will be released in the near future. Another unique feature of the Brazilian transfer pricing system is that royalties paid in consideration for the licensing of intangibles are not subject to transfer pricing rules although certain restrictions for deducting expenses with royalties are found in ordinary legislation.
It is also worth mentioning that the statutory language of Law No. However, Brazil being a civil law country, where the law expressly defines the meaning of imports and exports, certain transactions may not fall within such concepts contracts, certain intangibles, corporate reorganisations, etcetera.
This creates practical problems about whether certain transactions should, or should not, be subject to transfer pricing control. A recent change in the legislation was made whereby it was expressly defined that back-to-back transactions are also subject to transfer pricing control.
Another consequence of using the formulary apportionment system refers to advance pricing agreements APA. Although Brazilian companies are entitled to enter into an APA with the IRS, practically speaking such instrument only makes sense if a company does not comply with any of the methodologies set forth in the legislation.
In turn, the Brazilian IRS tends to be extremely conservative when approving anything that could lead to a reduction of the taxes to be paid by companies.
Consequently, APAs are rarely used in Brazil. Finally, Brazilian legislation only provides for primary transfer pricing adjustments.The Manifesto. The Communist Manifesto is a brief publication that declares the arguments and platform of the Communist party.
It was written in , by political theorists Karl Marx and. Data and research on transfer pricing e.g. Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, transfer pricing country profiles, business profit taxation, intangibles, The OECD and Brazil today launched a joint project to examine the similarities and gaps between the Brazilian and OECD approaches to valuing cross-border transactions between associated firms for tax purposes.
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At the same time.*Dual Transfer Pricing: Some firms choose the dual transfer pricing through the use of two methods of transfer pricing by separately to set the price of each transfer from one center to another.
Afterwards. An example of this was the Argentina Law.