Drawing Upon an Alternative Model for the Brazilian Transfer Pricing Experience : The OECD's Arm's Length Standard, Pre-Fixed Profit Margins or a Third Way?
Special attention has been paid to transfer pricing issues by the UN and the OECD in their tax agendas. Arguments relating to the arm's length standard in opposition to the formulary apportionment alternative have once again been raised. This article develops a legal analysis of the issue from the perspective of a developing country, namely Brazil. It addresses the reasons for the adoption in Brazil of a pattern supported by pre-fixed profit margins, the benefits and flaws of this pattern and the extent to which the country should follow the OECD's arm's length standard. In the author's opinion, the Brazilian pattern should be considered as a feasible alternative. On the one hand, it provides a high level of certainty and predictability, which is desired by Multinational Enterprises, together with the possibility of making adjustments to prevent distortions. On the other hand, the Brazilian pattern strengthens the taxing rights of developing countries. Such a conclusion is reached by bearing in mind both the UN Practical Manual on Transfer Pricing for Developing Countries and the OECD's Base Erosion and Profit Shifting project.This material was first published by Thomson Reuters (Professional) UK Limited in Marcelo Ilarraz, ‘Drawing upon an Alternative Model for the Brazilian Transfer Pricing Experience: The OECD's Arm's Length Standard, Pre-fixed Profit Margins or a Third Way?' (2014) 2 BTR 218, and is reproduced by agreement with the Publishers
Year of publication: |
2014
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Authors: | Ilarraz, Marcelo |
Publisher: |
[2014]: [S.l.] : SSRN |
Subject: | Brasilien | Brazil | OECD-Staaten | OECD countries | Verrechnungspreis | Transfer pricing |
Saved in:
freely available
Extent: | 1 Online-Ressource (19 p) |
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Type of publication: | Book / Working Paper |
Language: | English |
Notes: | In: British Tax Review, Vol 2 2014 Nach Informationen von SSRN wurde die ursprüngliche Fassung des Dokuments April 30, 2014 erstellt |
Source: | ECONIS - Online Catalogue of the ZBW |
Persistent link: https://www.econbiz.de/10013053613
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