Former Brazilian Tax Official Addresses Country’s Unique Methods

Elen Peixoto Orsini, a former auditor with the Brazilian Federal Revenue Service for over two decades and head of the transfer pricing inspection division of the Special Division for International Affairs from 2000-01, shared her views on a broad spectrum of Brazilian transfer pricing issues in a Aug. 9 interview. In written responses to questions from BNA Tax Management reporter Kevin Bell, Orsini discussed Brazil’s unique mathematical approach to transfer pricing, the nation’s recent tax haven legislation, the resale price minus profit method, the new thin capitalization legislation, and other matters. Orsini, who retired from the Federal Revenue Service in 2003, maintained her own international tax practice until joining Machado Associados in June 2010. Enjoying this article? To continue reading you need to take out a FREE trial to the Transfer Pricing Library.




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