MAP Auditores Independentes

MAP Auditores Independentes
A vision of future
Transfer Pricing
According to those standards, companies or individuals
resident or domiciled in Brazil, who perform operations with other
companies or individuals resident or domiciled abroad, deemed to
be related, or who are headquartered in tax havens (even through
an intermediary) are required to adopt the following calculation
rules in their operations:
Imports
“PIC” – Comparable Uncontrolled Price Method
(CUP)
“PRL” - 20% - Resale Price Method (RPM) 20%
“PRL” - 30% - Resale Price Less Profit 30%
“PRL” - 40% - Resale Price Method Less Profit 40%
“CPL” – Cost Plus Method (CPM)
“PCI” – Quoted Import Cost
What is Transfer Price
The expression "transfer price" has been used to
identify controls imposed on sales or financial operations
between related parties headquartered in different tax
jurisdiction, or operations involving a party
headquartered in a tax haven. Given the peculiar
circumstances surrounding those operations, the prices
used can be artificially determined and as suchdiffer
from market prices negotiated by unrelated parties,
under similar conditions, e.g., an arm´s length price.
Exports
“PVEx” - Export Sales Price (ESP)
“PVV” – Retail Sales Price Less Profit
“PVA” - Wholesale Price Less Profit (WSP)
“CAP” – Acquisition/Production Cost Plus Profit
“PECEX” - QuotedExportPrice
Calculation standards and methods
Impact on corporate business management
Currently, the regulations are dealt with by Law 9430/96, as
amended by Law 12.715/12 , and the Regulatory Instructions nos.
1.312/12 and 1.39513, issued by the “Receita Federal” (Federal
Income Tax Authority).
According to recent Answers to Advance Tax Ruling
Requests ( such as COSIT 13/2013) supporting
documents can be taken from audit reports, lists of
sales invoices and other sources, always stressing
the need for notarized/consularized translation of
foreign documentation.
São Paulo - Matriz
Rio de Janeiro - Filial
Av. Paulista, 2073 - Conjunto Nacional – Horsa I – cj. 2115
Avenida Nilo Peçanha, 50 – Ed. Rodolpho de Paoli – sala 2004
Tel.: (11) 3541-3545 / Tel.+Fax: (11) 3288-9191
Tel.: (21) 3559-2013 / Tel.+Fax: (21) 3559-2013
Celular: (11) 9 9963-7205
Celular: (21) 97409-6504
[email protected]
A MAP
This analysis and calculation is not only used
fiscal/tax purposes by accountants and tax
specialists to determine taxes payable. Rather it is
an analysis of high impact on corporate business
planning, sales price management and purchase
negotiation, and quite often, on determination of
the feasibility of businesses bearing tax expenses
which cannot be initially estimated.
Companies from several industries in Brazil have
been assessed for defaulting on pertinent
legislation, thus being subjected to heavy tax
burden.
With the recent expansion of accessory taxation
by electronic means in Brazil, companies are
increasingly exposed to inspection and assessment
by the taxing authorities, differently from what
prevailed especially among small and medium
businesses until shortly ago.
Highly experienced in this segment, MAP Auditores is prepared
to assist companies in selecting the most suitable method, making
the calculations required, and preparing documentation for filing
with the competent authorities, all in an independent and lawabiding manner.
Coupled with this experience is the use of several state-of-theart electronic tools intended to treat data in a thorough, efficient
way , ultimately reducing lead times and expanding the ability to
analyze information.
How to select a method and document foreign operations
Among the many calculation methods available, the most
suitable for a given company should only be selected after a careful
study of the company´s operations, margins expected and applied,
taxes levied, volume of operations, availability of supporting
documentation and other factors impacting the amounts arrived at.
São Paulo - Matriz
Rio de Janeiro - Filial
Av. Paulista, 2073 - Conjunto Nacional – Horsa I – cj. 2115
Avenida Nilo Peçanha, 50 – Ed. Rodolpho de Paoli – sala 2004
Tel.: (11) 3541-3545 / Tel.+Fax: (11) 3288-9191
Tel.: (21) 3559-2013 / Tel.+Fax: (21) 3559-2013
Celular: (11) 9 9963-7205
Celular: (21) 97409-6504
[email protected]