Transfer pricing calculations (transfer pricing study) shall be prepared annually and in accordance with local standards.
In Brazil, the transfer price analysis is necessary to enable qualified transactions and in accordance with the provisions of Law 9430/96 and Normative Instruction 1312/12.
The operations below will be subject to transfer pricing control, when carried out with individuals or legal entities resident or domiciled abroad, considered linked or even if not linked, located in countries of favored taxation or with privileged tax regime:
- importation of goods, services and rights;
- export of goods, services and rights;
- financial instruments.
Ideally, the transfer price calculation should be completed before the payment of income tax and social contribution due by the end of January of the year immediately following the calculation period. Fines and interest are charged in case of late payment.
Taxpayers should have the calculations and documentation necessary to support the information of the annual corporate tax return (ECF), typically delivered as of July 31 of the year immediately following the calculation.
To determine your transfer price calculations accurately and ensure they comply with the current legislation, please contact Mazars' taxation specialists. Our team has global expertise and works with solutions tailored to your operations.