REAd. Revista Eletrônica de Administração (Porto Alegre)
versão On-line ISSN 1413-2311
PEDO, Mônica Gisele Brancher; MULLER, Cláudio José e CORTIMIGLIA, Marcelo Nogueira. Calculation methods for transfer pricing on import operations and its impacts on tax. REAd. Rev. eletrôn. adm. (Porto Alegre) [online]. 2011, vol.17, n.1, pp. 270-297. ISSN 1413-2311. http://dx.doi.org/10.1590/S1413-23112011000100010.
As the global economy continues to expand and markets become more open to investment, enterprises share activities among their units established in different countries. The prices determination for the transfer of goods between affiliated companies situated in different tax jurisdictions is called Transfer Pricing. For tax purposes, transfer pricing determines the amount of income that each party earns and thus, the amount of income tax due in both the export and import countries, representing a relevant issue to the tax administrations in countries where these operations occur and to the companies which have units in more than one country. This study presents an analysis related to Transfer Prices practiced by a Brazilian company that imports raw material from its associated units established in other tax jurisdictions. A case study that shows this situation and the Brazilian Transfer Pricing rules are presented. The conclusion is that the company should apply more than one of the available calculus methodologies in order to identify which one results in the lower tax adjustment. In addition to that, it is concluded that the Transfer Pricing is an issue that depends on many variables that should be carefully analyzed for each situation or company, considering the particularities of each situation.
Palavras-chave : Transfer Pricing; Arm's Length (Fair Value); Raw Material Import; Associated Companies; Intercompany Transactions.