OrbitaxClarification on use of auction prices for transfer pricing purposes
|Approved Changes|Brazil
On 14 May 2007, a decision from the General Tax Coordination department (COSIT, Coordenação – Geral de Tributação) was published in the Brazilian Official Gazette which stated that sales carried out through a bidding process (licitações) are not considered as atypical transactions for transfer pricing purposes.
According to Art. 31 of Normative Instruction 243/2002…
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