Companies with 31st December as the financial year closing are obligated to submit a detailed disclosure form as well as Country-by-Country report where necessary before 30th April More than anything, the most important obligation for the companies remain to understand the complexities and requirements under the new bylaw and ensure all inter-company uncontrolled transactions are valued using the right transfer pricing method; prescribed under the guidelines.
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A hybrid system with rebuttable predetermined profit margins and limited functional analysis has been ruled out, since it would avoid double taxation, but at the cost of high tax complexity and increased potential for profit shifting and tax arbitrage. In conclusion, the result of the joint project between the OECD and the RFB is very comprehensive and reflect the limitations of Brazilian transfer pricing rules.
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The traditional dilemma formulary apportionment vs. Thus, the focal point is that the unilateral application of diverging transfer pricing rules may have negative consequences for businesses and, consequently, for economic development. It is now time for a political decision in Brazil, which should consider the findings of this survey that collected inputs from several MNEs headquartered in 11 different jurisdictions, while also weighing the pros and cons of the full adoption of the OECD TPG.
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Control with Fairness in Transfer Pricing
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