The New Transfer Pricing  in Brazil.
Gilda Almeida Gilda Almeida

The New Transfer Pricing in Brazil.

The Landing of the New Transfer Pricing Regulations in Brazil.

Brazil has published new transfer pricing (TP) regulations adopting the arm’s-length principle (Medida Provisória (MP) No 1.152).

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Foreign Tax Credits -The New Arm's Length Requirement
Gilda Almeida Gilda Almeida

Foreign Tax Credits -The New Arm's Length Requirement

The U.S. Chamber of Commerce and its Brazil-U.S. Business Council has asked Treasury for the immediate withdrawal, suspension, or modification of the new arm’s-length requirement in final foreign tax credit regulations, claiming that it is unjustifiably over-broad and punitive and that it could cause lasting damage to U.S. commercial and economic interests.

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