export price is higher than 90 percent of the sale price in the domestic price no adjustments may be done. Otherwise, one of the export price methods may be applied Sales Prices in Exports The Sales Prices in Exports Method(PvEx is the export version that utilizes compared independent prices. It involves the comparison of the average price of exports of the same resident company to independent parties or of other Brazilian exporters who are shipping to independent parties. Prices to b compared must make reference to equal or similar products and payment conditions In transactions dealing with commodities, stock exchange prices may apply under some considerations The main problem in applying this method is that it relies on the taxpayer accessing reliable data from independent companies, which can be difficult Wholesale price in the countr of destination Less profit The Wholesale Price in the Country of Destination Less Profit Method(PVA) is somewhat of an export version of the resale price less profit method, which is available for imports. Following this method the taxpayer must determine the average of the wholesale price of identical or similar goods charged in the country of destination, under similar payment conditions. This average reduced by the taxes included in the price that are collected in the country of To ascertain the legal transfer price, a profit margin of 15 percent must be subtracted from the wholesale price, as the following example illustrates Cin any tn country I s120 Adjust Related parties Retail Price in the Country of Destination Less profit Similar to the method above, the Retail Price in the Country of Destination Less profit Method(PW considers the average of the retail price of identical or similar goods charged in the country of destination, under similar payment conditions, but reduced by the taxes included in the price that are collected in the country of destination. Since no intermediary commerce is present, the gross profit margin applied to achieve the legal transfer price is 30 percent, which must be subtracted from the retail priceexport price is higher than 90 percent of the sale price in the domestic price, no adjustments may be done.18 Otherwise, one of the export price methods may be applied. Sales Prices in Exports The Sales Prices in Exports Method (PVEx)19 is the export version that utilizes compared independent prices. It involves the comparison of the average price of exports of the same resident company to independent parties or of other Brazilian exporters who are shipping to independent parties. Prices to be compared must make reference to equal or similar products and payment conditions. In transactions dealing with commodities, stock exchange prices may apply under some considerations. The main problem in applying this method is that it relies on the taxpayer accessing reliable data from independent companies, which can be difficult. Wholesale Price in the Country of Destination Less Profit The Wholesale Price in the Country of Destination Less Profit Method (PVA)20 is somewhat of an export version of the resale price less profit method, which is available for imports. Following this method, the taxpayer must determine the average of the wholesale price of identical or similar goods charged in the country of destination, under similar payment conditions. This average is reduced by the taxes included in the price that are collected in the country of destination. To ascertain the legal transfer price, a profit margin of 15 percent must be subtracted from the wholesale price, as the following example illustrates: Retail Price in the Country of Destination Less Profit Similar to the method above, the Retail Price in the Country of Destination Less Profit Method (PVV)21 considers the average of the retail price of identical or similar goods charged in the country of destination, under similar payment conditions, but reduced by the taxes included in the price that are collected in the country of destination. Since no intermediary commerce is present, the gross profit margin applied to achieve the legal transfer price is 30 percent, which must be subtracted from the retail price. B wholesaler in country 1 A in Brazil C in any country $ 198 $ 120 Wholesale price 198 - Taxes 154 - 15% Gross Profit 131 Adjustment (131-120) 11 Related parties