ABSTRACT
On 10 November 2016, the Brazilian Revenue Service issued guidance on the mutual agreement procedure in tax treaties. The ruling put an end to years of uncertainty and provided transparency to taxpayers, but it set conditions that deviate from treaties and brought no concrete perspectives for the conclusion of pricing agreements.
SCHOUERI, L. E.; BARBOSA, M. C. . Brazil – MAP Guidance Released by the Revenue Service. International Transfer Pricing Journal, v. 24, p. 1-6, 2017.