This rule may be controversial since it appears to institutionalize dumping practices, but no Brazilian company has made any real use of the exception because of the bureaucratic requirements. The result, other than what probably was the intention, is an undermining of efforts to promote Brazilian exports echnology Transfer Brazilian transfer pricing rules do not apply to royalties, technical, scientific, administrative, or similar assistance, which are governed by specific regulations. Deductibility of such costs and expenses is limited to ranges varying between 1 percent and 5 percent, depending on the type of industry or trade involved Documentation The major part of the work on documenting transfer pricing refers to the management of all transaction information during the fiscal year in order to fulfill the tax return requests. The tax return to be completed yearly must include inter alia o relation of all transactions and object of transfer pricing purpose: e identification and condition(relation) of the nonresident related parties, country, transaction,s value o applicability or not of one of the above studied safe harbors o total value of exports and imports to related parties(FOB values e total value of exports and imports to parties, related or not, resident in tax favored territories: e total value of exports and imports not included above commissions and brokerage on imports o insurance and royalties on imports o for exports and imports of goods or services, each transaction must be so described in order to allow its identification o for exports of goods, each must relate to the NCm code( Mercosul ommon Nomenclature, which are customs codes commonly used within Mercosul, the common market between Brazil, Argentina Uruguay, and Paraguay o the average transfer price applied in the period and the parameter price after using one of the methods; and 9 adjustments incurred Beyond the information to be added on the yearly tax return, Brazilian rules lo not specifically list what documents must be provided for transfer pricing purposes. Documentation requirements rely on the capacity of the taxpayer to demonstrate the consistent application of one of the prescribed methodsThis rule may be controversial since it appears to institutionalize dumping practices, but no Brazilian company has made any real use of the exception because of the bureaucratic requirements. The result, other than what probably was the intention, is an undermining of efforts to promote Brazilian exports. Technology Transfer Brazilian transfer pricing rules do not apply to royalties, technical, scientific, administrative, or similar assistance, which are governed by specific regulations. Deductibility of such costs and expenses is limited to ranges varying between 1 percent and 5 percent, depending on the type of industry or trade involved. Documentation The major part of the work on documenting transfer pricing refers to the management of all transaction information during the fiscal year in order to fulfill the tax return requests. The tax return32 to be completed yearly must include inter alia: relation of all transactions and object of transfer pricing purpose; identification and condition (relation) of the nonresident related parties, country, transaction's value; applicability or not of one of the above studied safe harbors; total value of exports and imports to related parties (FOB values); total value of exports and imports to parties, related or not, resident in tax favored territories; total value of exports and imports not included above; commissions and brokerage on imports; insurance and royalties on imports; for exports and imports of goods or services, each transaction must be so described, in order to allow its identification; for exports of goods, each must relate to the NCM code (Mercosul Common Nomenclature, which are customs codes commonly used within Mercosul, the common market between Brazil, Argentina, Uruguay, and Paraguay; the average transfer price applied in the period and the parameter price after using one of the methods; and adjustments incurred. Beyond the information to be added on the yearly tax return, Brazilian rules do not specifically list what documents must be provided for transfer pricing purposes. Documentation requirements rely on the capacity of the taxpayer to demonstrate the consistent application of one of the prescribed methods