Transfer price is a tax statement for proving that the price practiced in operations with companies based abroad, considered related parties (intercompany) or, even if not related, reside and are domiciled in countries with favored taxation (tax haven), meet the rules set forth by law and regulations issued by the Internal Revenue Service of Brazil.

In Brazil, the Internal Revenue Service requires that the price practiced intercompany with entities based abroad is arbitrated by Brazilian Transfer Price standards, since the country is not an OCDE member and does not follow doctrine commonly adopted in most developed countries.

Legislation addressing Transfer Prices determines the following methods applicable to different transactions, whether importation or exportation:


  • Independent Compared Prices – PIC
  • Resale Price minus Profit – PRL
  • Cost of Production plus Profit – CPL
  • Price under Quotation in Importation - PCI


  • Cost of Acquisition or Production plus Taxes and Profit – CAP
  • Sale Price in Exportations – PVEx
  • Sale Price for Wholesale in the Country of Destination, Deducted from profit - PVA
  • Retail Sale Price in the Country of Destination, Deducted from Profit - PVV
  • Price under Quotation in Exportation - Pecex

Our professionals work in conjunction with the client, performing consulting work, reviews or preparation of calculations for presenting results that allow assertive compliance with Transfer Price obligations in operations with entities abroad, as well as correct information of the results of these calculations to the Internal Revenue Service of Brazil.

We provide support to companies in analyzing their intercompany foreign operations (importation or exportation of goods, services and rights), pursuant to the applicable tax provisions, especially Law # 9.430/96 and subsequent amendments, relative to Transfer Pricing.

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Daniel Souza
Partner | Direct Tax
Daniel Souza
Learn more about our Expert
Daniel Souza
Partner | Direct Tax
Daniel Souza

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