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Northwestern Journal of International Law & Business

Comparative and Foreign Law

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New Transfer Pricing Rules In Brazil, Alexandre Tadeu Seguim Jan 1999

New Transfer Pricing Rules In Brazil, Alexandre Tadeu Seguim

Northwestern Journal of International Law & Business

Through transfer price, the organization aims to evaluate and improve the performance of the related entity. The idea that transfer pricing is a mechanism designed only to avoid taxes is misleading. Actually, to transfer price is a sound and positive way to increase value. The 1979 OECD Report on Transfer Pricing and Multinational Enterprises emphasized that the term is neutral: "the consideration of transfer pricing problems should not be confused with the consideration of problems of tax fraud or tax avoidance, even though transfer pricing policies may be used for such purposes." The 1995 OECD Report went even further by …