Brazil: Transfer Pricing Rules on Imports Clarified
Private Ruling 95/2018, published in the Official Gazette, clarifies some aspects of transfer pricing rules related to importing products into Brazil. The key points are:
- Transfer pricing rules still apply to the import of products for internal sale (whether subject to industrialization in Brazil or not) if the resident importer and the resident exporter are related parties.
- Price under import quotation method is required if the imported product is classified as a commodity under Brazilian tax law.
- If resale-price-less-profit method is allowed, the profit margin must be applied as determined under normal benchmarking analysis.