Brazil has recently released Private Ruling 1001 of 9 January 2018 regarding the deduction of certain cross-border payments to a foreign subsidiary, including strategic decision support, information management, risk management and management of the supply chain and acquisitions constitute remuneration for the provision of services and, as beneficiary of a related person. In order for payments for such services / activities to be deductible, the activity must be necessary for the benefit of the Brazilian company, and the transfer price of the costs must be determined according to the uncontrolled pricing method or the cost-plus method.