Advance Pricing Agreement Brazil



-November 30, 2020-

Advance Pricing Agreement Brazil

Mike Burroughs

While a POP may co-exist with domestic legal or administrative disputes, the subjects must, when submitting the original application, inform and prove that the tax issue to be considered under the POP has been submitted for judicial or administrative analysis in Brazil or the other contracting state. These include all pre-price agreements (APAs), private rulings, tax rulings, etc. In implementing the POP solution, subjects must waive ongoing administrative or judicial remedies. As noted in the OECD communication, a proposed transfer pricing in Brazil was announced in February 2018 to verify the differences between Brazilian transfer pricing rules from OECD standards. The results of the project were published in a December 2019 report. The report identifies two options for Brazil to move closer to the OECD standard while improving the positive features of its existing framework for offset transfer pricing. Both options consider full compliance with the principle of arm length, while striving to preserve simplicity and safety. TaxNewsFlash Read The country has a pre-price program (APA)? If so, is the program widespread? Are there unilateral, bilateral and multilateral APAs? In Brazil, there is no prior price agreement (APA). The Organisation for Economic Co-operation and Development announced today that the OECD secretariat and Receita Federal do Brasil (RFB) have launched an investigation into the implementation phase of a joint transfer pricing project between the OECD and Brazil to collect public contributions to inform work on the development of safe ports and other simplification measures and measures that could help improve tax security. In this context, it is envisaged to include targeted safe ports in appropriate circumstances. Safe ports - simplified approaches to determining or bringing the price closer to arm length - can offer advantages in terms of simplicity and safety if they are designed correctly (in accordance with the principle of arm length) and applied in appropriate circumstances (under certain eligibility criteria).

They also reduce the cost to taxpayers of complying with tax rules and contribute to more effective tax management and security. Other measures and practices can also contribute to tax security in situations where safe ports are not an appropriate instrument.


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