Brazil: Mandatory transfer price calculation


published on 18 January 2022 | reading time approx. 1 minute



Entities that have import and/or export operations with related parties, are subject to the Transfer Pricing rules, as per IN No. 1312/12. Such operations must be registered in the Tax Accounting Bookkeeping, through the authorization of the relevant records in the taxation parameters. The tax adjustment must be added to the IRPJ base on December, even if the Brazilian taxpayer calculates taxable income quarterly.


In the Real Profit system, the taxpayer is subject to fines provided for by law for non-compliance with the rules regarding the Transfer Price. The fine can reach 3 per cent of the omitted, inaccurate or incorrect amount, in this way, the penalty can be of great materiality for the taxpayer who fails to provide the transfer price information in the ECF.


We are at your disposal to assist in filling out these records and delivering the ancillary obligation in accordance with the Transfer Pricing calculations.

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Philipp Klose-Morero

Managing Partner South America

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Rafael Silveira Martins

Associate Partner

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