© 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 Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.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
Simon Associates Management Consultants: Bringing Anthropology Into Business
Innovation
20/03/2019Simon Associates Management Consultants: Bringing Anthropology Into Business

Simon Associates Management Consultants (SAMC) is an innovative consultancy firm drawing on the vast business and academic experience of its founder, Dr. Andrea (Andi) Simon. We caught up with Andrea to find out more about the firm and learn about the secrets

Read Full PostRead - Eye Icon
Patents: Storming the World of IP
Legal
19/01/2015Patents: Storming the World of IP

First Thought IP Ltd is a full-service intellectual property law firm that advises on patents, designs and copyright, licensing and litigation issues.

Read Full PostRead - Eye Icon
HMRC splashes a quarter of a million training staff to be hackers
Strategy
20/05/2021HMRC splashes a quarter of a million training staff to be hackers

HM Revenue & Customs has spent £262,251 on cyber security training for its staff over the two most recent financial years, according to official figures. This data was obtained and analysed under the Freedom of Information (FOI) act by the Parliament Stre

Read Full PostRead - Eye Icon
Leader in Research and Development – North Wales
Innovation
27/09/2022Leader in Research and Development – North Wales

We’ve all experienced a bad smell at some point in our lives, whether it’s from pets, children, leaky sewerage, or other people’s food in the office.

Read Full PostRead - Eye Icon
How to Measure and Prove the ROI of Corporate Innovation: A CFO’s Guide
Finance
19/12/2025How to Measure and Prove the ROI of Corporate Innovation: A CFO’s Guide

CFOs often hold the weight of the company on their shoulders. Leadership might question the need for new tools and technology updates. Successful brands may pause before making changes that deviate from the status quo. Yet, without significant changes, growth

Read Full PostRead - Eye Icon
CTC Media, Inc. Announces Receipt of Final Tranche of Purchase Price for Business Sale
Finance
12/02/2016CTC Media, Inc. Announces Receipt of Final Tranche of Purchase Price for Business Sale

CTC Media, Inc. announced today that it has received the final tranche of the purchase price for its sale of 75% of the outstanding participation interests in its subsidiary CTC Investments LLC to UTV-Management LLC.

Read Full PostRead - Eye Icon
MUFG Investor Services to Acquire Capital Analytics from Neuberger Berman
Finance
04/02/2016MUFG Investor Services to Acquire Capital Analytics from Neuberger Berman

MUFG Investor Services, the global asset servicing group of Mitsubishi UFJ Financial Group, has reached an agreement with Neuberger Berman, one of the world’s leading private, employee-owned investment managers, to acquire its private equity fund administrat

Read Full PostRead - Eye Icon
The Best Innovations for the Best Metalwork
Innovation
08/08/2022The Best Innovations for the Best Metalwork

Working in one of the most demanding markets in the world, Retech has become a global leader in metallurgical processing equipment supply.

Read Full PostRead - Eye Icon
Mac 101- Why Does Apple Consider them as the Best Choice for Businesses?
News
16/11/2021Mac 101- Why Does Apple Consider them as the Best Choice for Businesses?

Mac devices have been increasing in popularity in business for numerous years. Companies like IBM and Axel Springer opt for Mac rather than PCs. Why do companies opt for Mac?



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