TRANSFER PRICE: APLICABILIDADE NA COMPANHIA VALE

Abstract

This article provides an overview of transfer pricing and its usefulness within the Vale company. Displays specific subjects related to the calculations and regulations used in import and export operations referring to the relevant parties that are headquartered in different tax jurisdictions or in a tax haven. It has the term Transfer Price by principle of verification and identification that the related activities are in compliance with the rules established by law and normative acts issued by the IRS. Vale maintains its focus on the opportunity cost, where it proves to be effective its measurement in the economic result, comparing internal costs with prices practiced in the market, subject to adjustments regarding terms, location, intermediation costs between others. A conclusion is presented with a focus on export operations carried out in the organization, enhancing the practices used, including aspects resulting from the wrong price practiced in these operations, in which they can be artificially stipulated and consequently diverge from the negotiated price, occurring erosions of countries' tax bases or double taxation.