MAP Guidance Released by the Revenue Service

Journal
Schoueri, L.E.; Barbosa, M. Calicchio
Brazil
International Transfer Pricing Journal 2017 (Volume 24), No. 4
FormatPDF
EUR
40
| USD
45
(VAT excl.)

On 10 November 2016, the Brazilian Revenue Service issued guidance on the mutual agreement procedure in tax treaties. The ruling put an end to years of uncertainty and provided transparency to taxpayers, but it set conditions that deviate from treaties and brought no concrete perspectives for the conclusion of pricing agreements.