© 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 Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.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
November Winners’ Directory
Finance
02/12/2016November Winners’ Directory

November Winners’ Directory

Read Full PostRead - Eye Icon
Fairly and Forcefully Represented
Legal
09/10/2017Fairly and Forcefully Represented

Fairly and Forcefully Represented

Read Full PostRead - Eye Icon
Owed money? Can you deal with it yourself without engaging a solicitor?
Finance
Read Full PostRead - Eye Icon
ClearlySo Raises £1.25 Million in Equity as Octopus Takes a Major Stake
Finance
14/06/2016ClearlySo Raises £1.25 Million in Equity as Octopus Takes a Major Stake

London, United Kingdom - ClearlySo, Europe’s leading impact investment bank, announced today that Octopus has taken a 12.3% stake in the company as part of a £1.25 million growth funding round. Octopus, a fast-growing UK fund management company and the larg

Read Full PostRead - Eye Icon
Ciena Acquisition of Certain TeraXion Assets
Finance
19/01/2016Ciena Acquisition of Certain TeraXion Assets

Ciena® Corporation, the network specialist, has entered into a definitive agreement with TeraXion Inc. to acquire its high-speed photonics components (HSPC) assets for approximately USD $32 million (CAD $46.6 million) in cash.

Read Full PostRead - Eye Icon
How to Start a Publishing Company: 8 Important Steps
News
09/08/2024How to Start a Publishing Company: 8 Important Steps

Creative freedom, increased clout, and potential profit. These three reasons to start your own publishing company may fuel your decision to take that step, but they do little to help you understand everything that goes into it. Writers who choose to self-publi

Read Full PostRead - Eye Icon
NLRB Micro-Union Decision Causes Untold Harm to Retail
Leadership
30/04/2015NLRB Micro-Union Decision Causes Untold Harm to Retail

The National Labor Relations Board’s decision to recognize a micro-union of workers in just a single department at a Macy’s store in Massachusetts rather than the entire store violates longstanding precedents on union organizing, said the NRF.

Read Full PostRead - Eye Icon
AXG Group and AHR Private Wealth Announce Merger to Continue Strong Growth In 2020
M&A
22/07/2020AXG Group and AHR Private Wealth Announce Merger to Continue Strong Growth In 2020

International financial advisory firm AHR Private Wealth has today announced an acquisition agreement, subject to local regulatory approval, with London-based AXG Group. The AXG Group companies’ will integrate into the AHR framework, while continuing to prov

Read Full PostRead - Eye Icon
Zenith Hygiene Group Enters into Formal Agreement to Acquire CCL Pentasol
M&A
17/06/2016Zenith Hygiene Group Enters into Formal Agreement to Acquire CCL Pentasol

Acquisition will allow Zenith Hygiene to enter new markets, further strengthening its position in the UK and driving value for its customers.



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