The Brazilian Federal Revenue Department issued Normative Instruction (NI) 1568/15 on June 8, 2015. This has restricted the application of the cost adjustments in the calculation of the transfer price based on the Brazilian commodities methods applicable to imports and exports. According to this provision, a taxpayer may perform an appropriate analysis based on contracts acquired within its economic group provided they were concluded with unrelated parties, or may use contracts obtained from public databases.
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