© Copyright Acquisition International 2025 - 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 Another is that the mathematics required for imports of goods used in production processes under the repealed Law 9,950/00 usually resulted in small taxable adjustments when the levels of value added to these raw materials were significant.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
Navigating Personal Injury Claims: The Role of a Queens Personal Injury Attorney
Legal
30/05/2023Navigating Personal Injury Claims: The Role of a Queens Personal Injury Attorney

Life can sometimes throw unexpected challenges our way. One such unexpected event can be a personal injury. These incidents can change our lives dramatically, causing not only physical pain but also emotional trauma and financial burden.

Read Full PostRead - Eye Icon
Cloud-Based Management Systems Designed to Inspire and Empower
Innovation
07/08/2024Cloud-Based Management Systems Designed to Inspire and Empower

Enabling organisations through its suite of pioneering management systems, IQMS Australasia, offers a highly refreshing approach when it comes to management solutions.

Read Full PostRead - Eye Icon
The History and Basics of Cost Segregation (Cost Seg)
Finance
22/02/2023The History and Basics of Cost Segregation (Cost Seg)

Cost segregation has a long and varied history, with its roots stretching back to the late-1800s. The concept was initially used as a way to help business owners save money on their taxes by splitting assets into different categories and leveraging the varying

Read Full PostRead - Eye Icon
Why So Many More Businesses Are Making the Choice to Become More Eco-conscious
Corporate Social Responsibility
23/01/2023Why So Many More Businesses Are Making the Choice to Become More Eco-conscious

Now more than ever we are hearing of businesses taking a more eco-conscious route when it comes to their daily practices. This could be the energy they use, employee and customer incentives, recycling, planting greenery, and so on.

Read Full PostRead - Eye Icon
Copperstone Capital
Finance
28/10/2015Copperstone Capital

Copperstone Capital is an investment management firm founded in 2010 in Moscow by David Amaryan.Copperstone Capital manages wealth for high net worth individuals and institutions and provides advisory services.

Read Full PostRead - Eye Icon
Saga Welcomes Osborne’s Inheritance Tax Reforms
Finance
09/07/2015Saga Welcomes Osborne’s Inheritance Tax Reforms

In a poll of more than 10,000 over 50s two thirds (65%) thought that the main family home should be excluded from inheritance tax calculations.

Read Full PostRead - Eye Icon
Pensions Used as an Investment Vehicle for Good
Finance
17/08/2021Pensions Used as an Investment Vehicle for Good

Saving for retirement is a distant prospect that only becomes real the closer we get to it, wishing we had started to save seriously earlier. However, could this be about to change for many?

Read Full PostRead - Eye Icon
Defining Corporate Governance in 2016
Finance
24/06/2016Defining Corporate Governance in 2016

The following roundtable, the second in a series sponsored by Hawksford, discusses corporate governance and its role in the financial services industry, with a specific focus on Asia. Helping us to tackle some of the most pertinent issues are four leading fina

Read Full PostRead - Eye Icon
Advancements in Food Safety
Innovation
05/12/2019Advancements in Food Safety

iFoodDecisionSciences, Inc. (iFoodDS) is a leading provider of food safety risk management software solutions for the produce supply chain. Recently, we caught up with the firm’s CEO, Diane Wetherington who provided us with a glimpse into the best food safet



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