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Brazilian Federal Revenue Service publishes public consultation regarding proposed transfer pricing regulations applicable to intragroup services and advance pricing arrangements

|Tax Alerts, National/Federal Taxation, Transfer Pricing, Global|Brazil
Brazil
  • The proposed regulations intend to restrict the mark up applicable to intermediation services.
  • The proposed regulations include further details on the benefit tests.
  • Besides dealing with transfer pricing matters related to services, the rules also cover the application of the withholding tax on intermediation services.
  • A completely new set of regulations are proposed for advance pricing agreements (APAs), with some limitations being proposed that had not been anticipated in former publications by…

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