© 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 Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.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
Why Do Judges Hand Out Multiple Life Sentences?
Legal
21/09/2022Why Do Judges Hand Out Multiple Life Sentences?

This article will discuss what this type of punishment is and how courts reach their decision to hand such sentences to law offenders. This write-up will also cite examples of people with these “back-to-back” life sentences.

Read Full PostRead - Eye Icon
Scaling Your Brokerage Business in 2024: Adopting Trends from LATAM’s Fintech Revolution
News
08/04/2024Scaling Your Brokerage Business in 2024: Adopting Trends from LATAM’s Fintech Revolution

Source: Pexels.com If you’re looking to level up your connections and gain fresh perspectives, iFX EXPO events are the place to be! These educational conferences bring thousands of finance whizzes and trading titans together in major metro areas each yea

Read Full PostRead - Eye Icon
Sullivan & Cromwell Advise CVS Health’s Purchase of Omnicare
Legal
08/07/2015Sullivan & Cromwell Advise CVS Health’s Purchase of Omnicare

Sullivan & Cromwell Advise CVS Health's Purchase of Omnicare

Read Full PostRead - Eye Icon
Insurance Company Approached You To Settle A Claim: Here’s What To Do
News
07/03/2022Insurance Company Approached You To Settle A Claim: Here’s What To Do

If you have been injured in an accident, you are probably in a lot of pain. You may have to attend multiple doctor’s appointments and miss plenty of work. You just want this all to be over with and to get back to your normal life.  When an insurance

Read Full PostRead - Eye Icon
Procam’s Acquisition of HotCam
Finance
28/05/2015Procam’s Acquisition of HotCam

Procam's Acquisition of HotCam

Read Full PostRead - Eye Icon
New Merger & Acquisition Guidance Aims to Minimise Climate Risk From Sales of Oil, Gas Assets
M&A
17/02/2023New Merger & Acquisition Guidance Aims to Minimise Climate Risk From Sales of Oil, Gas Assets

The energy sector is, for obvious reasons, the key area of concern for climate change. Can new guidelines for M&A prioritise emissions reductions?

Read Full PostRead - Eye Icon
Cruz Marcelo & Tenefrancia
Finance
31/08/2016Cruz Marcelo & Tenefrancia

Cruz Marcelo & Tenefrancia is a full-service firm with proven expertise in different practice areas such as corporate and commercial law, intellectual property, litigation and dispute resolution, to name just a few.

Read Full PostRead - Eye Icon
Integrating Knowledge Management into Business Growth Strategies
Strategy
20/10/2025Integrating Knowledge Management into Business Growth Strategies

Knowledge is one of the most valuable assets that a company can possess in today’s fast-paced business environment. From internal processes to customer insights, businesses generate and consume large amounts of data every day. But simply possessing this

Read Full PostRead - Eye Icon
US Unique in the World as to Its Bankruptcy Laws
Legal
30/11/2016US Unique in the World as to Its Bankruptcy Laws

The United States is unique in the world as to its bankruptcy laws. No other country gives its ordinary citizens the ability to start fresh, without debt, without stripping them of almost all their possessions.



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