Brazil has published Normative Instruction RFB No. 2090 of 22 June 2022 on the declaration and control (inspection) of the customs value of imported goods, including specific references to transfer pricing. The Normative Instruction includes rules for the application of the transaction value (actual price) method for determining the customs value of imports, with specific rules on the conditions for using the transaction value method, the determination of the actual price paid or payable, and different transaction value adjustments. Among the conditions for using the transaction value method, it is provided in the case of imports involving a sale between related persons, the use of the transaction value method is only allowed if the buyer can demonstrate that the relationship with the seller did not influence the price. This condition also applies in cases where a third party acts as an importer on behalf of the buyer.
Source Orbitax
