At the 90th minute (or 11th hour to those in the U.S.) of 2022, the Brazilian government issued draft legislation to align Brazil’s transfer pricing regulations with the international standards set by the OECD Transfer Pricing Guidelines.
Julia Vasconcellos
Julia Vasconcellos (LL.M.) is an attorney with over a decade of experience in transfer pricing and currently serves as a senior consultant in RoyaltyStat. She earned her J.D. in 2008 and LL.M. in international civil procedure and intellectual property law in 2012 from Universidade Federal do Espírito Santo.
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Comparable Royalty Rates
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Julia Vasconcellos
Transfer pricing based on comparables is the foundation of the U.S. Treasury Regulations (“Treas. Reg.”) § 1.482 (published in 1994, as amended), the OCED Transfer Pricing Guidelines (1995, 2010), and several other country-specific transfer pricing regulations around the world.
In theory, the Treas. Reg. § 1.482 and the OECD Guidelines list five factors of comparability with a pretty nomenclature that read objective and reasonable. They are characteristics of property or services, functions performed, contractual terms, risks assumed, and economic conditions (geographic market).
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- Topics: Comparability Analysis
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