Fiscal Transfer Price in Brazilian Exporting Companies: A Contingencial Approach

Abstract

This article aims to investigate the transfer pricing methods adopted by Brazilian exporting companies for fiscal purposes based on contingency factors - environment, strategy, size, technology and structure. The study is characterized as descriptive, with a quantitative approach, performed through questionnaires applied to 90 companies listed in the Brazilian Exporters Catalog. The results show that, among the companies that import linked products, the most used method is based on the price of resale minus profit (PRL), while among the exporting companies the method of cost of acquisition or production plus taxes and profit (CAP) is the most commonly employed. Less-verticalized companies, located in a more stable, centralized, smaller, and lower technological level tend to use similar methods in import and export operations, making it easier to control and prove the method employed in cases of supervision.

Keywords

• preço de transferência fiscal
• fatores contingenciais
• empresas exportadoras