Transfer pricing calculations (local transfer pricing study) must be prepared annually under local rules. In Brazil, the transfer pricing analysis are required for all transactions qualified under the provisions of Law 9430/96 and NI 1312/12.
The transactions performed with related parties (companies or individuals) abroad and or with parties that are resident or domiciled in favored tax or privileged tax countries, are subject to transfer pricing analysis:
- Import of goods, services and rights
- Export of goods, services and rights
Ideally, the transfer pricing calculation must be concluded before the income tax and social contribution payments are due by the end of January of the immediately following year to the calculation period. Fines and interests are charged in case of late payment.
Taxpayers should have the calculations and documentation necessary to support the information filed as part of the annual tax return (ECF), normally up to July 31st of the immediately following year to the calculation period.
Mazars is available to our customers to answer questions on this important topic. Contact our team for more details about our services.
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