The article comments on the new transfer price rules created by Brazilian Federal Law #11,727 (published 23 June 2008) on its adoption of the "harmful tax practices" concept to apply the transfer price rules to all transactions between Brazilian entities and foreign companies subject to lower taxation in their home jurisdictions. The new concept overrules the former concept of "blacklisting" tax heaven jurisdictions and submits to the rules even entities located in high tax jurisdictions in cases where they are granted a favoured tax regime.

21 July 2008



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