© 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 Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.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
Investment Management of the Future
News
20/06/2023Investment Management of the Future

EXtrance is revolutionising the real estate fund sector with state-of-the-art technology. The company was founded in 2020 by real estate investment expert, William Lively.

Read Full PostRead - Eye Icon
Top 7 Services Which Will Help Your Marketing Team Flourish in 2023
News
27/02/2023Top 7 Services Which Will Help Your Marketing Team Flourish in 2023

Are you concerned about expanding your company because you’ve put quite some effort into it? Well, if you are, you’re not making a wrong decision in doing so.

Read Full PostRead - Eye Icon
Cyber-Security in the M&A Process
Legal
22/06/2016Cyber-Security in the M&A Process

During an M&A deal process huge amounts of sensitive data is shared in the cyber-space between buyers, sellers and their respective advisors. Infringement of this data’s cyber-security could leave parties open to significant claims.

Read Full PostRead - Eye Icon
How To Choose A Cloud Service For Your Small Business
Innovation
02/12/2022How To Choose A Cloud Service For Your Small Business

Running a small business nowadays requires careful consideration, especially with the technology used. If you want to maintain an edge in your industry, cloud technology is something to keep in mind. Cloud services allow convenient accessibility of data. Keep

Read Full PostRead - Eye Icon
ShipEngine and What3words Partner to Enhance Online Delivery Experiences
M&A
26/07/2024ShipEngine and What3words Partner to Enhance Online Delivery Experiences

ShipEngine, a leading shipping API, today announces that it has partnered with innovative location technology what3words, enabling seamless deliveries and strengthening the online customer experience. From today, what3words has been added to ShipEngine’s rob

Read Full PostRead - Eye Icon
A Strong Footing in the Stock Market: Exploring Investment Strategies
Finance
10/03/2022A Strong Footing in the Stock Market: Exploring Investment Strategies

Standing at about $93 trillion, the stock market seemed primed for a next mega move that could thrust its valuation to over $100 trillion--or better. This is impressive, but what are the best strategies to become a part of this super wave?

Read Full PostRead - Eye Icon
Transparency, Integrity, Communication, Kindness
Corporate Social Responsibility
08/08/2022Transparency, Integrity, Communication, Kindness

Founded in 1996, Edkey Inc is a non-profit organisation which manages 28 schools and programmes across Arizona including 17 Sequoia Charter Schools. It works together with families to provide high quality educational services for their K-12 children by creatin

Read Full PostRead - Eye Icon
Strong Management More Important Than Ever in UK
Innovation
29/10/2019Strong Management More Important Than Ever in UK

We are experiencing a resurgence in the popularity of tough bosses in the UK. The “Imperial CEO” started to become less fashionable in the eighties with the decline in deference. The nineties saw the reputation of strong business leadership tarnished with

Read Full PostRead - Eye Icon
Allen & Overy Advises on Exim India’s Inaugural U.S. Dollar Green Bond
Finance
06/05/2015Allen & Overy Advises on Exim India’s Inaugural U.S. Dollar Green Bond

Allen & Overy has advised Bank of America Merrill Lynch and J.P. Morgan as joint bookrunners on Export-Import Bank of India’s inaugural USD500 million Regulation S green bond issue.



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