PwC Tools

• Business Model Restructuring;
  
  
• Combined analysis of commercial import and export flows, in addition to price policies;
  
  
• Selection of the best method approach for Transfer Pricing and Customs Valuation, pursuant to pertinent legislation;
  
  
• Analysis of the Transfer Pricing system in relation to taxation of results accruing overseas, international agreements drawn up between Brazil and other countries, among others.

Transfer Pricing and International Trade Consulting work covers the following:

• Preparation of consultations on Transfer Pricing legislation, either on a theoretical basis or relating to an actual client situation;
  
  
• Assistance in building complementary elements to evidence prices charged, pursuant to item II, art. 29 of IN SRF 243/02 (technical research) or requests for percentage alterations (art. 32 da IN SRF 243/02);
  
  
• Support for export prices under ninety percent of the average prices charged in Brazil, pursuant to art. 30 of IN SRF 243/02 (gaining new markets);
  
  
• Customs clearance with consequent time reduction and cash flow enhancement, by sorting and mixing Special Customs Regimes;
  
  
• Import and Export Duty reduction through the correct employment of International Agreements.
  
  

• Advisory services
  
  Optimization of the import tax burden
  Import price analysis
  Expediting customs clearance
  Reduction of imported merchandise inventory carry over
  Processing by international order
  Domestic content ratio analysis
  Triangular operation analysis
  
  
• Compliance
  
  Import tax calculation basis
  Accounting for operations by account and order
  Certification and statements of origin
  Accounting records on imports
  
  

• Advice on implementing outsourced technological tools or those developed by the company;
  
  
• Review of the practical application of Transfer Pricing methods determined by the client with the aid of electronic tools (data extractor, among others) or on a conceptual basis (criteria/procedures review);

• Guidance on preparing the documents requested by the tax authorities in tax assessment procedures;
  
  
• Monitoring tax assessment hearings, including meetings with the financial authorities, as the client’s tax advisor.

• Preparation of calculations, studies, research, and other documents requested by the client’s legal advisors to support and back up administrative and judicial cases.

• Generic legislation;
  
• Practical application of legislation;
  
• Integration of legislation in the company’s specific case (presentations and seminars).