© 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 Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.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
Secure Business Payments now available from PaymentEvolution
Finance
30/07/2015Secure Business Payments now available from PaymentEvolution

Pay suppliers, vendors and any open invoice directly to any bank account.

Read Full PostRead - Eye Icon
AI and the New Era of Personalized Marketing: Strategies for Success
News
20/08/2025AI and the New Era of Personalized Marketing: Strategies for Success

Artificial intelligence is changing how businesses connect with their customers. Personalized marketing is now an expectation.

Read Full PostRead - Eye Icon
CVC Capital Partners Acquisition of PKP Energetyka
Finance
03/08/2015CVC Capital Partners Acquisition of PKP Energetyka

CVC Capital Partners Acquisition of PKP Energetyka

Read Full PostRead - Eye Icon
Procurement Fraud: The Corporate Landscape’s Nemesis
Strategy
29/04/2019Procurement Fraud: The Corporate Landscape’s Nemesis

As bakery chain Patisserie Valerie plunges into administration following allegations of fraud from third party contractors, we explore the issues around procurement fraud and how it can be prevented.  Fraud within any area of a business is a devastating occur

Read Full PostRead - Eye Icon
GDPR: What you need to know
Finance
28/03/2018GDPR: What you need to know

From 25 May 2018 the Data Protection Act 1998 (DPA) will be replaced by The General Data Protection Regulation (GDPR), and it will bring important changes to the ways data is stored and processed by businesses.

Read Full PostRead - Eye Icon
Manufacturing Sector ‘Enduring a Real Struggle’ Says EY ITEM Club
Finance
10/09/2015Manufacturing Sector ‘Enduring a Real Struggle’ Says EY ITEM Club

Research from multinational professional services firm EY suggests a slowdown in gorwoth in the manufacturing sector for the 3rd quarter of 2015.

Read Full PostRead - Eye Icon
Cleanroom Innovation
Innovation
10/05/2022Cleanroom Innovation

Founded in 1993 by Gernod Dittel, DITTEL Engineering GmbH has over the years grown alongside the cleanrooms market. The importance and excellence of firms such as DITTEL Engineering has been significantly highlighted during the pandemic, with the massive incre

Read Full PostRead - Eye Icon
How Does Journalism Work in the Age of Deepfakes?
News
31/01/2024How Does Journalism Work in the Age of Deepfakes?

Trigger Warning: This article mentions child sexual abuse and drug use. Journalism has existed ever since people first banded together in complex social groups. From cave drawings telling primitive band communities about discoveries and new hunting grounds, th

Read Full PostRead - Eye Icon
Creating A Lead Generation Strategy From Cold To Hot Leads
News
05/09/2022Creating A Lead Generation Strategy From Cold To Hot Leads

The lifeblood of any business is finding new clientele while retaining your old ones.  Customers are like the focal point where the two arms of a business rest. On the one side are new customers; on the other are returning 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