© Copyright Acquisition International 2026 - All Rights Reserved.

Article Image - Challenges and  Alternatives for the  Brazilian Importer
Posted 27th May 2015

Challenges and Alternatives for the Brazilian Importer

We hear from Carlos Ayub as he talks us through the challenges and alternatives for the Brazilian importer under the transfer pricing regulations.

Mouse Scroll AnimationScroll to keep reading

Let us help promote your business to a wider following.

Challenges and Alternatives for the Brazilian Importer
Image

Challenges and Alternatives for the Brazilian Importer

We hear from Carlos Ayub as he talks us through the challenges and alternatives for the Brazilian importer under the transfer pricing regulations.

Since the enactment of the Brazilian transfer pricing regulations, the Resale Price Less Profit (PRL) Method has historically been the method most used by taxpayers to evidence their compliance with the pricing of import transactions, since the local law does not require the Best Method Rule (except for commodity transactions), thus allowing a taxpayer to choose the preferred method.

There are several reasons for electing mostly the PRL method. One of them is the fact that its use does not depend on information that is outside the entity’s own recordkeeping environment. Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.

However, with the enactment of Law 12,715/12, a new rationale was introduced for the PRL method, which disregards the value added in Brazil and uses a formula to prorate the cost of the imported raw material to the cost of the finished product. That tweak in the formula, for most taxpayers, resulted in significant increases of the taxable adjustments, despite the reduction in the new profit margins required in a large part of the cases.

Furthermore, the PRL is more susceptible to foreign exchange effects, as the ones that the Brazilian economy has experienced in recent months, since its equation starts with a resale price in Brazilian reals and its outcome is a price that is compared to the price of the actual import in foreign currency.

Thus, importers that until then used exclusively the PRL method should now consider the possibility of using different methods, such as the Comparable Independent Prices (PIC) method and the Production Cost plus Profit (CPL) method, the supporting documentation of which, especially in the latter case, is complex, laborious, and depends on information obtained from their foreign related parties.
Therefore, even though the PRL method should continue being the starting method in most cases, we suggest that other methods are taken into consideration to be applied exclusively on imported items that are subject to taxable adjustments, as an alternative to reduce or even eliminate such adjustments.

Note that there are major complexities and challenges in this area, which tend to increase, especially if we add to them the highly computerised resources that the Brazilian Federal Revenue Service has, and continues to expand to oversee these transactions.

In this context, the assistance of specialists with practical experience on these matters, as well as the use of cutting edge, proven technology is mandatory to find new paths that result in a reduced financial burden, within legal limits.

Categories: Finance, Innovation


You Might Also Like
Read Full PostRead - Eye Icon
Improve Your  Membership Management In 3 Easy Steps
Leadership
01/08/2023Improve Your  Membership Management In 3 Easy Steps

If you are looking for ways to improve your membership management, then look no further. In this blog post, we will discuss three easy steps that you can take to ensure that your membership management system is running as efficiently and effectively as possibl

Read Full PostRead - Eye Icon
A Calgary Driver’s Legal and Medical Roadmap After a Car Accident
Legal
25/06/2026A Calgary Driver’s Legal and Medical Roadmap After a Car Accident

Protect your health and claim after a car accident in Calgary with a clear legal and medical checklist from an experienced lawyer.

Read Full PostRead - Eye Icon
Commercial and Private Client Advisory Services
Strategy
29/02/2016Commercial and Private Client Advisory Services

Veale Wasbrough Vizards (VWV) is a UK top 100 law firm with offices in London, Bristol, Birmingham and, from 1 February, Watford. We are a full service firm in our locations offering commercial and private client advisory services, with a national presence in

Read Full PostRead - Eye Icon
New Store Setup Checklist: 5 Vendors to Hire (+ Timeline and Top-Rated Options for Each)
Strategy
29/09/2025New Store Setup Checklist: 5 Vendors to Hire (+ Timeline and Top-Rated Options for Each)

Opening a new store is exciting, but it can also feel like juggling flaming torches while balancing on a ladder — every detail matters and timing is everything. Your launch depends not just on vision and location, but on the vendors you hire and when you hir

Read Full PostRead - Eye Icon
Forget GameStop, gamification is the real investing revolution
Strategy
05/03/2021Forget GameStop, gamification is the real investing revolution

The impact on the financial world was sensationally underlined in the US, when a swathe of retail investors sought to bring down eminent hedge funds by bidding up the beleaguered GameStop stock. Behind the David and Goliath headlines, are some trends that the

Read Full PostRead - Eye Icon
White & Case Advises Saudi Automotive Services Company on Acquisition
Legal
08/07/2015White & Case Advises Saudi Automotive Services Company on Acquisition

White & Case Advises Saudi Automotive Services Company on Purchase

Read Full PostRead - Eye Icon
How to Improve Efficiency at Your Warehouse
News
25/03/2024How to Improve Efficiency at Your Warehouse

How to Improve Efficiency at Your Warehouse Meta: How do you improve efficiency at your warehouse? Read our tips to find out. INSERT IMAGE: https://images.unsplash.com/photo-1586528116022-aeda1613c63d?q=80&w=1771&auto=format&fit=crop&ixlib=rb-4

Read Full PostRead - Eye Icon
5 Strategies to Maximize Commercial Real Estate Revenue
News
01/07/20225 Strategies to Maximize Commercial Real Estate Revenue

Looking for ways to maximize your revenue if you work in commercial real estate is constant. You can do a lot to boost your income, but it's also possible to make mistakes that hurt your bottom line.

Read Full PostRead - Eye Icon
5 Steps to Improve Your Chances of Obtaining a Business Loan
Finance
19/06/20235 Steps to Improve Your Chances of Obtaining a Business Loan

It’s easy to assume that lenders won’t consider your personal financial situation when you’re trying to obtain a loan for your business. After all, your personal financial situation might have no bearing on your ability to manage money in your profession



Our Trusted Brands

Acquisition International is a flagship brand of AI Global Media. AI Global Media is a B2B enterprise and are committed to creating engaging content allowing businesses to market their services to a larger global audience. We have a number of unique brands, each of which serves a specific industry or region. Each brand covers the latest news in its sector and publishes a digital magazine and newsletter which is read by a global audience.

Arrow