Brazil - Recent Case Law on Transfer Pricing: Still in Need of an Autonomous Concept of “Production”
- L.E. Schoueri; R.A. (Jr.) Galendi
- International Transfer Pricing Journal, 2018 (Volume 25), No 3
- 1 May 2018
This article discusses the recent Eli Lily case, as decided by the Brazilian Administrative Court. It provides a brief overview of the Brazilian transfer pricing method applicable to this case and describes the tax assessment by the tax authorities before analysing the decision of both the Administrative Court and its Superior Chamber.