Transfer pricing


Transfer Pricing

Deloitte supports your company’s adherence to the Brazilian Transfer Pricing legislation

We rely on experienced professionals and advanced technologies, such as the new TPS, a faster and more flexible version of the widely employed and recognized Transfer Pricing assessment and management software.

What is the Transfer Pricing legislation?

It is a set of rules applicable to Brazilian taxpayers making trade and financial transactions with parties abroad, such as company headquarters and companies within the same economic group; or operating with companies located in tax havens holding exclusiveness over operations, although not related. Application of the legislation is compulsory and demands detailed calculations that must be submitted to the Brazilian Internal Revenue Service. Failure to comply with the rules may generate relevant tax adjustments, plus fines and interests.

What is the legislation main objective?

The main objective of the Transfer Pricing legislation is to inhibit loss of revenue by the Brazilian government, caused by the practice of price favoring between companies subjected to these rules. 

In practice, what can we do to support your company in this area?

Using the New TPS, a specialized team assesses and manages your company’s transfer pricing, aiming at compliance with the legislation and identification of risks and opportunities. For this purpose, we:

  • Assess and review companies’ Transfer Pricing calculations (imports, exports and interests);
  • Automatic Transfer Pricing data entry in the Income Statement (DIPJ/ECF);
  • Analysis of legal alternatives aiming at reducing tax adjustments as a consequence of Transfer Pricing;
  • Support in preparing administrative safeguards in response to tax deficiency notices;
  • Diagnosis of company operations that may be impacted by the Transfer Pricing legislation;
  • Licensing of the New TPS assessment software;
  • Consulting on specific issues related to Transfer Pricing management;
  • Training on Transfer Pricing;
  • Review of Transfer Pricing assessments prepared by your company;
  • Consulting on other specific matters related to the topic.

Key contact

Carlos Ayub

Carlos Ayub

Transfer Pricing Leader

With more than 24 years of solid professional experience, today he is the responsible for Deloitte´s Transfer Pricing services in Brazil.... More