Transfer pricing (TP) is based on many principles - the essential one is the Arm ́s Length Principle (ALP), In this respect, the term "associated persons" is of crucial importance: associated persons must be involved in transactions in order for the ALP to be applied, The aim of the paper is to...

The UN Practical Manual on Transfer Pricing for Developing Countries endeavors to provide “clearer guidance on the policy and administrative aspects of applying transfer pricing analysis.” Chapter 10 is particularly noteworthy. It sets out specific country practices. The rules in Brazil,...

In this article, the author discusses Brazil's unique transfer pricing regime in light of the country's request to become an OECD member, examining how Brazil's system differs from the OECD's and how the process may even inspire changes to the OECD's transfer pricing rules

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...

In this article, the author explains how Brazil’s transfer pricing methods, which rely heavily on fixed margins, can be reconciled with the OECD’s transfer pricing guidelines and how emerging economies can benefit from the resulting system

In the context of BEPS Action Plans 8, 9, 10 and 13, related to Transfer Pricing Policy and Documentation, we present an analysis on its interactions with the existing anti-avoidance and protection rules to prevent base erosion currently in force. Brazil is a country that has always presented...