© 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 Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.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
What You Need to Know About Microsoft 365 Copilot, the Ultimate AI Assistant
Innovation
25/01/2024What You Need to Know About Microsoft 365 Copilot, the Ultimate AI Assistant

Microsoft 365 Copilot is the new AI powered solution from Microsoft, and it looks set to revolutionise the way we work. Microsoft have this week announced they are removing the 300-seat purchase minimum for commercial plans and making Microsoft 365 Copilot ava

Read Full PostRead - Eye Icon
Pandora to Acquire Key Assets from Rdio
Innovation
17/11/2015Pandora to Acquire Key Assets from Rdio

Adding technology, IP and talent to accelerate development of new capabilities.

Read Full PostRead - Eye Icon
Technology Aftermarket Support Secures Success
Innovation
23/03/2020Technology Aftermarket Support Secures Success

Technical services and aftermarket support have become an increasingly important battleground for technology manufacturers as the expectations of consumers and end-users continue to rise. Rising to meet them is Qcom, a support partner which delivers these serv

Read Full PostRead - Eye Icon
CEO of the Year – New Jersey
Innovation
02/02/2016CEO of the Year – New Jersey

The Macaluso Group (“TMG”) is a technology and data driven company focused on pioneering co-pay and financial payment solutions.

Read Full PostRead - Eye Icon
Exciting IT Innovations to Watch in 2024
Innovation
11/03/2024Exciting IT Innovations to Watch in 2024

Digital innovation never ends, and the groundbreaking trends that defined 2023 will continue to shape the world around us. With technology evolving at a greater pace than ever before, 2024 already looks to be another exciting year for IT innovation.

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
The 2017 Onshore Excellence Awards Press Release
Strategy
26/04/2017The 2017 Onshore Excellence Awards Press Release

The 2017 Onshore Excellence Awards Press Release

Read Full PostRead - Eye Icon
Acquisition International is Proud to Announce the Winners of the 2023 Research & Development Awards
News
28/09/2023Acquisition International is Proud to Announce the Winners of the 2023 Research & Development Awards

United Kingdom, September 2023 – Leading B2B publication, Acquisition International, reveals the winners within this year’s edition of the Research & Development Awards.

Read Full PostRead - Eye Icon
Christmas cancelled for nearly half of SMEs
Leadership
18/12/2015Christmas cancelled for nearly half of SMEs

Zurich’s latest SME Risk Index reveals nearly half (49%) of SME decision makers have worked on Christmas Day.



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