The planning of and compliance with accessory obligations and transfer pricing calculations are important topics for companies that carry out transactions with related parties and, especially, for multinationals.

The adoption of appropriate policies on transfer pricing can mitigate the risks of tax assessments and reduce the transaction costs for groups operating in various jurisdictions.

Brazil has transfer pricing calculation methods that generally differ from those adopted in other countries as it is relatively more objective and adopts fixed margins.

Moreover, the international transfer pricing rules are quickly and constantly changing due to actions such as the BEPS (Base Erosion and Profit Shifting), within the scope of the Organization for Economic Cooperation and Development (OECD).

With our expertise, which combines the Brazilian laws and the standards adopted in international conventions, we provide a differentiated service to assist our clients in performing all obligations related to this matter.

Highlights of our work:

  • Consulting in transfer pricing solutions
  • Planning of the transfer pricing calculation implementation
  • Advisory in related-party transactions and intercompany transactions
  • Advisory in loan and financing transactions with interest paid or received abroad
  • Assessment of the impacts from the BEPS/OECD actions on transfer pricing
  • Transfer pricing calculation
  • Advisory in compliance with accessory obligations
  • Advisory in the preparation of the Country-by-Country Report