Silvania Tognetti, Brazil, Pereira Neto, Galdino, Macedo Advogados ...

Margins in Transfer Pricing
Unique in the world: aims to achieve the arm´s length
standard by making use of a series of safe harbors and
fixed formula.
Taxpayer is faced with a tough practical reality: he would
need to apply one price in order to fit into the Brazilian
transfer pricing standards, and another different price, in
order to attend the OECD transfer pricing regulation.
Certainty of Brazilian system: development of an
objective methodology to reduce risk of assessment.
Safe harbors in exportation limit the number of taxpayers
that must demonstrate Transfer Pricing accomplishment.