• Service: Tax, Global Transfer Pricing Services
  • Type: Regulatory update
  • Date: 10/23/2013

Brazil - Adjustments to commodity prices in related-party transactions 

October 23: Guidance published by the tax authority of the State of São Paulo concerns procedures for determining the pricing of commodity exports and imports.

RFB Normative Instruction No. 1,395 (13 September 2013) relates to the pricing of exports (Preço de Cotação na Exportação—PECEx) and of imports (Preço de Cotação na Importação—PCI) for commodity transactions. In general, the guidance provided relates to price adjustments with respect to transactions involving related parties.

New variables to be considered for adjustments in commodity prices include: (1) the payment terms; (2) the quantities traded; (3) “climatic influences” on the characteristics of the imported commodities; (4) intermediation costs in the purchase and sale applied by unrelated persons; (5) packaging, and (6) freight and insurance.

Read a September 2013 report (Portuguese) prepared by the KPMG member firm in Brazil: Tax News: Preços de Transferência - Instrução Normativa RFB nº 1.395 de 13/09/2013

For more information, contact a tax professional in Brazil :

Marienne Coutinho

Eliete Ribeiro

Henry Conti

Evandro Tibao

Ricardo Roa

Edson Costa

Contact a tax professional with KPMG's Global Transfer Pricing Services.

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