TRANSFER PRICING METHODS IN BRAZIL

The present paper outlines the methods used to measure the transfer price of goods and services (tangibles and intangibles) between associated enterprises in Brazil. This shall be accomplished by studying international guidelines and legislation, such as the OECD transfer pricing guidelines. Due to the lack of national doctrine relating to the theme, an analysis of international doctrine will be applied. As Brazil has not ratified the OECD tax model or guidelines, an analysis of the Brazilian TP methods will be presented along with a study of the possible application of these methods to national and international transactions in Brazil.