transfer pricing brazil
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Brazil Adopts Thin Capitalization Rules
... loans instead of direct equity investments in order to transfer funds to finance the activities of their Brazilian subsidiaries. However, ... 9.430, of December 27, 1996, which introduced the transfer pricing regulations in Brazil ... 3. Under Brazilian law the consortium and the ...
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Deduction Of Royalties In Intragroup Transactions
... wrongful decision of the highest level of Brazil's tax administrative court1 (CSRF, Decision ... to royalties of 5% instead of other transfer pricing rules methods), involving the Brazilian ...
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The Double Role of Financial Covenants in Bond Issues in Brazil.
... of securities and that they have different implications for the pricing process. Evidence to support these hypotheses has been reported by Chang ... levels, paying excessive dividends, or taking other actions that transfer wealth from creditors to shareholders (Smith & Warner, 1979) ...
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Managing Corporate Taxation in Latin American Countries - Brazil (Part I)
... sum of all royalties, technical assistance and other technology transfer payments due cannot exceed percentages varying from 1% to 5% of the net ... 1.1.2.4. Transfer Pricing Rules ... Such rules apply to the following transactions, if carried out ...
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Some New Ideas on the Role of Legal Analysis applied to the Regulation of Telecommunications Services in Brazil
Purpose - The paper aims to present new ideas and analytical approaches developed in recent years by Brazilian legal scholars regarding regulation and economic development. Regulatory law of telecommunications services is taken as an example of application of such new ideas and analytical approaches. Methodology/approach/design - Two main approaches to the relationship between law and economic...
... and services of the real economy and (ii) the transfer of money or other forms of liquidity. The latter belongs both to the web ... Empirical data on actually delivered speed, actual pricing of service and actual social coverage in Brazil were not readily ... -
Atuais controvérsias no direito tributário internacional
... name of the enterprise, or b) for the transfer of the ownership of, or for the granting of the ... Brazil’s absence from the Multilateral BEPS Convention ... íses a lançarem mão do uso de Advanced Pricing Agreements 37 , uma es- ... Noeses, 2013, p ...
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Some New Ideas on the Role of Legal Analysis applied to the Regulation of Telecommunications Services in Brazil
Purpose - The paper aims to present new ideas and analytical approaches developed in recent years by Brazilian legal scholars regarding regulation and economic development. Regulatory law of telecommunications services is taken as an example of application of such new ideas and analytical approaches. Methodology/approach/design - Two main approaches to the relationship between law and economic...
... and services of the real economy and (ii) the transfer of money or other forms of liquidity. The latter belongs both to the web ... Empirical data on actually delivered speed, actual pricing of service and actual social coverage in Brazil were not readily ... - Petrobras changes pricing policy but uncertainty remains
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Franquicias multiunidades y gobernanza relacional: un estudio de las redes operativas en Brasil
La relación entre los mecanismos de gobernanza relacional y las franquicias de unidades múltiples, donde un único franquiciado posee y opera múltiples unidades, ha recibido atención limitada en la literatura existente. Estudios anteriores se centran principalmente en el papel de la confianza en tales acuerdos. En consecuencia, este estudio tiene como objetivo desarrollar y probar un modelo...
... : A study of operating networks in Brazil ... INTRODUCTION ... The franchising model ... Similarly, franchisors’ pricing and market share objectives may conlict with ... impact on performance, including the transfer of knowledge, monitoring, and socialization ... -
Multinacionalidade, ativos intangíveis e agressividade fiscal
Atualmente, a agressividade fiscal e a multinacionalidade tem sido temas recorrentes em pesquisas internacionais na área contábil. O objetivo deste estudo é analisar como a agressividade tributária (BTD ou TTVA) é afetada pela multinacionalidade, considerando o nível de ativos intangíveis das empresas listadas na B3. Para isso, foi realizada uma pesquisa quantitativa a partir da análise de...
... sets of companies listed on B3 (Brazil stock exchange). For this, a quantitative ... managerial and tax objectives in transfer pricing. The Accounting Review , 79 (3), ... -
Good News from Mass Media Induces More Investments in the Equity Crowdfunding Market.
... vc) in Brazil, which is the 9th largest economy and one of most ... Hornuf, L., & Neuenkirch, M. (2017). Pricing shares in equity crowdfunding. Small Business ... The Journal of Technology Transfer, 47, 1640-1661 ...
- Presidential candidates advocate new social welfare policy
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The (in) viability of green tax reform in Brazil
The green tax reform would be a viable reform in Brazil? Faced with this question, this article discusses the elements on which it based environmental taxation, citing the ongoing experiences of other countries, and any criticism of such a reform model. From these parameters, the green tax reform is analyzed within the Brazilian context, considering essentially the considerable regressivity of...
... taxation can o൵er, besides valuing the natural resource, its pricing and the internalization of the costs of environmental externalities, is a ... experience, Denmark, still in the 1990s, made the progressive transfer of the burden on income and labor for the exploitation of natural ... -
Sharing economy: becoming an Uber driver in a developing country.
... passenger, in the city of Belo Horizonte, Brazil. In the fifth part, we present the categories ... cultural aspects are undermined by pricing and profit principles that can be found in ... own client portfolio, they would not transfer 25 percent of the profit of each ride to Uber ...
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Competition law and neoliberalism: the regulation of economic concentration in Brazil/Direito da concorrencia e neoliberalismo: a regulacao da concentracao economica no Brasil.
... did not imply an increase of market power, but solely a transfer of ownership from a monopolistic or oligopolistic company to a substitute ... , establish supply commitments, impose restraints on predatory pricing and prevent the use of exclusive and/or long term contracts, among others, ...
- Shortage of diesel threatens Brazil, former ANP director says
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Regulation Of Financial Transfer Pricing
... may deduct from Corporate Income Taxes (IRPJ/CSLL) calculation bases, when the creditor is either an affiliated company domiciled outside Brazil, or a resident of a tax haven jurisdiction ... When the creditor is a Brazilian company and the debtor is either an affiliated company domiciled ...
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Operating Model and Estimation of the Insurance Premium for an Energy Futures Clearing House in Brazil.
... marking the position of customers to the market and ensuring the transfer of amounts according to the result of the operation, associated with their ... 2.2 Energy futures: risk premiums and pricing ... A classic approach to explaining commodity futures prices, where ...
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Recognizing the public right to healthcare: the approach of Brazilian courts
This paper considers aspects of the judicialization of health care policy in Brazil. It discusses the issue in the context of the separation of the powers of government, judicial protection of the public right to healthcare, the so-called “technical administrative discretionary prerogatives,” and finally, the need for a budget to provide for the efficacy of court decisions. To further the...
... judicialization of health care policy in Brazil. It discusses the issue in the context of the ... in one jurisdiction and enable their transfer to another jurisdiction.”) ... Revista de ... -regional courts of social and healthcare pricing – that have jurisdiction over disputes related ... -
Agenda 2030 measurements and finance. Interaction of International Investment Law and Sustainability
... Paulista, Brazil. Email: danielle.denny@yale.edu ... Douglas ... can also have know-how and technology transfer, increasing linkages between the domestic ... , and put in place negative externalities pricing ... The rush to return to the pre crises ...
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Benchmarking e governança global como parâmetros para a análise de programas de integridade
... main features of compliance programs in Brazil and into some elements of comparative lawǤ ... das multinacionais suscitamǤ Dz Transfer pricing policies permeate many facets of an ...
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Technology environment and crowdfunding platforms in Brazil.
... a platform is closely related to the network effects, which affect pricing strategies. These effects influence the propensity of actors to adopt the ... -governmental organizations and impeding the rapid and efficient transfer of resources between countries. It should be noted in this scope that the ...
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Environmental law & competition law: conflicts & complementarities from an environmental economics perspective
The aim of this paper is to evaluate whether environmental restrictions or requirements are considered in competition law. Common sense conceives that a company that bears costs of complying with environmental requirements experiences increased costs and seeks to transfer it to the prices of its products. A possible consequence of this behavior is its effects upon the competitive position of the...
... experiences increased costs and seeks to transfer it to the prices of its productsǤ A possible ... in the production processǤ It would be a pricing mechanism and consideration of the polluter pays ... and underdeveloped onesǤ Howeverǡ in Brazil there is a lack of studies that seek to highlight ... - Central Bank chief sees environmental issues affecting financial flows
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Multi-Unit Franchising and Relational Governance: A Study of Operating Networks in Brazil.
... Similarly, franchisors' pricing and market share objectives may conflict with franchisees' profitability ... direct and indirect positive impact on performance, including the transfer of knowledge, monitoring, and socialization processes that facilitate the ...