Private Ruling 9/2012 (Solução de Consulta 9/2012) (PR 9/2012), published in the Official Gazette of 13 November 2012, confirmed the Federal Revenue Service's position that the transfer pricing rules apply to back-to-back transactions.
Background
Within the context of PR 9/2012, back-to-back transactions are those where a Brazilian resident entity acquires goods from a non-Brazilian resident entity and, simultaneously, sells those goods to another non-Brazilian resident e…