Thursday, May 23, 2013

Brazil Changes Transfer Pricing Margins, Declines to Apply Rules to Mining Sector

Ed Taylor

RIO DE JANEIRO—Brazilian President Dilma Rousseff Sept. 18 sanctioned a major tax law that—among other things—changed the calculation of profit margins for products imported from related companies, but vetoed an article that would have applied the transfer pricing rules to the mining sector.

Law 12715 reduced the profit margin used to determine the taxation on imported industrial inputs, lowering it from the previous level of 60 percent to either 20 percent, 30 percent, or 40 percent, depending on the business sector. The same 20-30-40 percent categories were set for finished products…

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