Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 9/18/2012

Brazil - Status of pending transfer pricing changes 

September 18:  Brazil’s Congress has approved Provisional Measure No. 563/2012 which contains changes to the transfer pricing rules.

In Brazil, a Provisional Measure is an “act” issued by the president, with the authority of law until later approved by Congress. The Provisional Measure is effective as from its date of publication for 60 days, and it may be extended for an additional 60-day period (for a total of 120 days) on a request from Congress.


Provisional Measure (MP) Nº 563 (3 April 2012) includes changes affecting Brazil’s transfer pricing rules concerning the resale price method, and includes new transfer pricing methods for import / export commodity transactions, and changes to the rules for interest on related-party loans, among other items. For details, see TaxNewsFlash-Transfer Pricing: Brazil - Changes to transfer pricing rules


While the changes will be effective beginning 1 January 2013, taxpayers may elect to apply these new rules in 2012.



For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services group in Brazil:


Eliete Ribeiro

+55 11 2183-3288


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




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