Transfer Pricing

Transfer Pricing is the tax mechanism that aims to control international transfers between related persons, applicable to goods, services, rights or interest. 

This control basically aims to reduce or give the inspection bodies control of operations that can be characterized as overpriced (imports) or under-invoiced (exports).

The calculation of Transfer Pricing is based on methods defined and described in the tax law, indicating the deductibility in the calculation of the Taxable Income and CSLL the amount that does not exceed the price determined by one of the methods.

Our work consists of:

a) Identification of the obligation to determine transfer pricing

Application of the relevant law to identify the actual obligation in determining and evidencing transfer pricing.

b) Identification of methods that can be used

Analysis, based on the methods described in the relevant law, and, based on the information made available by the Company’s management, of the methods for determining the possible pricing parameter.

c) Determination of the parameter price and comparison with the practiced price

Elaboration of electronic spreadsheets, indicating the calculated parameter prices, comparing them with the prices practiced and indicating, when necessary, the adjustments in the tax calculations (IRPJ and CSLL), of the respective years.