Provisional Measure 478 (PM 478) was published in the Official Gazette of 29 December 2009. PM 478 introduced several amendments to transfer pricing rules.
The main amendment concerned the change of the methodology to calculate the Resale price method (previously called Preço de Revenda menos Lucro – PRL, and currently called Preço de Venda menos Lucro - PVL), which is based on the weighted mathematical average of the sales price.
The PRL was su…