Brazil recently published Private Ruling 1001 of 9 January 2018 concerning the deduction of certain cross-border payments to a foreign group entity, including for strategic decision support, information management, risk management, and supply chain and acquisitions management. In order for payments for such services/activities to be deductible, the activity must be necessary, useful, and for the benefit of the Brazilian company and the transfer price of the expense must be determined using t…