Brazil's New Transfer Pricing Method to Combat Tax Evasion on Commodities.
Aggressive tax planning, like shifting profits to low-tax areas, is a common issue. Countries combat this using transfer pricing rules and OECD's BEPS Action Plan. Developing countries, especially traditional commodity traders, face challenges in controlling transfer pricing on commodity transactions. The Brazilian "sixth method" for transfer pricing in commodities is compared to OECD guidelines in Action 10. The goal is to see if Brazilian laws align with OECD standards, especially in using the arm's length standard to allocate profits between related parties and combat base erosion.