Pinheiro Neto Advogados has one of the leading transfer pricing practices within the Brazilian market, representing national and multinational companies at administrative and judicial litigations. The team also provides general legal advisory on transfer-pricing matters, including planning, audit, tax treaties, APA’s and MAP’s. Senior associate Felipe Cerrutti Balsimelli is a key individual within the transfer pricing practice.
Over the research period, the TP practice provided litigation for Schaeffler Brasil in a transfer pricing dispute with the Brazilian tax authorities regarding federal taxation on imports carried out between Schaeffler’s Brazilian subsidiary and related parties in Germany. It also litigated in a transfer pricing dispute for Japanese automobile manufacturer Honda.