Volume 46 (2018) / Issue 11

Ricardo Marozzi Gregorio, 'Country note: Brazilian Transfer Pricing Rules: An Analysis of Effectiveness' (2018) 46 Intertax, Issue 11, pp. 914–929


Brazil is widely recognized as the most significant country that does not follow the international transfer pricing standards. Despite its practicability, there are many evidences that the Brazilian approach is ineffective when it comes to prevent tax avoidance in cross-border transactions. In fact, the predetermined margins combined with the free choice of methods are nothing more than the materialisation of the OECD’s warning against ‘opening avenues for tax planning’. The country’s announced intention of joining the OECD membership is now the great opportunity to amend and improve the current regime.

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ISSN: 0165-2826
ID: TAXI2018097