© 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 Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.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
Nordic Capital Acquires RESMAN
Finance
01/04/2015Nordic Capital Acquires RESMAN

Nordic Capital acquire RESMAN

Read Full PostRead - Eye Icon
How Will the Autumn Budget Affect Small Businesses?
News
18/11/2024How Will the Autumn Budget Affect Small Businesses?

How Will the Autumn Budget Affect Small Businesses? The Autumn Budget is here, and small business owners are wondering what the new measures mean for them. From tax rates to energy relief, these changes will likely impact your day-to-day operations and bottom

Read Full PostRead - Eye Icon
How to Decide Whether an MSP is Right for Your Business
Innovation
11/01/2023How to Decide Whether an MSP is Right for Your Business

You might have heard the term "MSP" used in conversation, or seen it in the news and wondered what it's all about. In the below article, we'll discuss what a managed service provider (MSP) is, how they can help your business and the steps you should consider t

Read Full PostRead - Eye Icon
The Role of Private Detectives in UK Employment Dispute Resolutions
News
04/08/2025The Role of Private Detectives in UK Employment Dispute Resolutions

The Role of Private Detectives in UK Employment Dispute Resolutions You caught your employee working from home at the beach again? Yeah, that’s not only you. In this era of hybrid work culture, it is not always simple to see the truth behind workplace pr

Read Full PostRead - Eye Icon
Enhancing Legal Compliance: The Role of YouTube Converters in Content Regulation
News
01/07/2024Enhancing Legal Compliance: The Role of YouTube Converters in Content Regulation

The rapid growth of online media and content-sharing platforms like YouTube has revolutionized how content is created, distributed, and consumed. Alongside these advancements, YouTube converters allow users to download and convert videos into different formats

Read Full PostRead - Eye Icon
Over a Third of International Employers Do Not Offer Enough Health and Wellbeing Benefits and This Impacts Their Recruitment and Retention
News
12/03/2025Over a Third of International Employers Do Not Offer Enough Health and Wellbeing Benefits and This Impacts Their Recruitment and Retention

In research issued by Towergate Employee Benefits, over a third (37%) of companies with employees based outside of the UK stated that they do not offer enough health and wellbeing support and that this impacts their ability to recruit and retain people.

Read Full PostRead - Eye Icon
The 8 Best Coworking Spaces for Tech Startups
Innovation
24/02/2021The 8 Best Coworking Spaces for Tech Startups

Startup companies in the information technology sector need space to collaborate and innovate. In-person and remote meetings require a specialized office, but new businesses may not be able to invest in a permanent location. These are the best eight coworking

Read Full PostRead - Eye Icon
Simplifying Asset Performance Management
Finance
22/07/2019Simplifying Asset Performance Management

Atonix Digital develops and offers a suite of software solutions to help businesses and utilities to boost efficiency, increase the accuracy of planning, and to improve day-to-day decision-making in an everchanging landscape

Read Full PostRead - Eye Icon
How to Drive More Foot Traffic to Your Business
News
01/03/2024How to Drive More Foot Traffic to Your Business

For your small business to thrive, you need to make sure it’s fed with interested customers each day. The more people you lead to your doors, the better your revenue numbers get. That’s because foot traffic includes customers who are either curious



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