Rivitti e Dias Advogados is a law firm focused on tax law with services including advisory, consulting, administrative and judicial dispute resolution services regarding tax law for Brazilian and foreign individual and corporate clients from various business sectors. The tax advisory practice offers solutions for new business models, with an emphasis on the optimization of the tax burden and the management of risks.
During the research period, the firm advised its client on the legal provisions on transfer pricing adjustments. This case reflects the ongoing change in Brazilian transfer pricing legislation. Although the Provisional Presidential Decree has yet to be approved, the new criteria introduced in the legislation are still subject to discussion – especially regarding their application by the Brazilian Federal Revenue Service.
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