Change Country

International Businesses

Brazil Issues Legal Guidance on Safe Harbor Rules

Posted on February 19, 2013 by

Sue Tuson

Sue Tuson

Share This

On January 18, 2013, the Brazilian tax authority issued Legal Guidance 1.321/2013 providing transfer pricing safe harbor rules applicable to transactions involving exporting of goods for fiscal year 2012 (retroactive) and 2013.

2012 safe harbor transfer price for exports to related party will be met if net pre-tax profit of the Brazilian seller on such sales is at least 5% of the average gross sales revenues of the previous three years. The taxpayers may elect to calculate the 5% safe harbor based on actual sales revenue for the current year or the arithmetic average (based on a formula provided under the rules)  of the sales revenues for the last three years.

2013 safe harbor transfer price for exports will be met if net pre-tax profit on export sales of at least 10% of export sales revenues. The government has released the mechanics of calculating the safe harbor for 2013.

Share This

Sue Tuson


As an international tax advisor, Sue helps businesses structure their operations globally to mitigate tax costs and maximize profits.

Related Insights

Don’t Overlook International Tax Compliance

Managing international operations, employees and contractors requires a high level of due diligence to ensure that all return filing and payments are completed before their deadlines. Adhering to all requirements and making certain that each calculation is accurate may require significant time, especially as we approach the end of the year. 

by Eric Lin

Bringing Mobility to Detroit

We’re excited to share this news from the Detroit Regional Partnership. For companies needing help planning mobility focused expansion to the US – from the UK, Europe or Asia, there is a well-connected team to help with all aspects of foreign direct investment.  Learn more about how we can help here.

by Teresa Gordon

The Future of Global Mobility Tax

The global mobility landscape is changing. What began as a need to work from home during the worldwide pandemic is evolving into a “work from anywhere” trend that appears to be here to stay. Learn how this impacts the competition for talent and multi-jurisdiction tax compliance.

by Teresa Gordon

The Sound of Automation Podcast

Industrial automation businesses are the driving force behind Industry 4.0, and Clayton & McKervey is here to help.

Skip to content