Corporate taxation

The corporate tax rate in Brazil is 34%.

Transfer pricing

Brazil’s transfer pricing rules define maximum price ceilings for deductible expenses on inter-company import transactions and minimum gross income floors for inter-company export transactions.
The Arm’s Length Principle governs the Brazilian Transfer Pricing legislation. However, there is no direct reference to the arm’s length principle or its Portuguese translation in the transfer pricing legislation in Brazil. For example, the Explanatory Statement of the Law 9430/1996 which introduced the Transfer Pricing Rules in Brazil says the law conforms rules adopted by OECD member countries. The TPG can be used as a subsidiary interpretation guidance, whenever it does not contradict the Brazilian transfer pricing legislation and the national legal system.


Transfer Pricing Case Law

Case NameDescriptionDateCourtKeywords