circumstances.2 Taxpayers or a class entity may request a change by demonstrating inter alia the whole annual effective buying and selling gisters involved in the solicitation and its respective freight and insurances paid. The rules also require documentation that shows changes in rates. For his requirement, taxpayers may use e publications and reports issued by the govemment of the sellers or purchaser's country, or a statement of that same country when Brazil and that country have entered into a convention for the avoidance of double taxation or an agreement for the exchange of information; or e market research conducted by a recognized, technically qualified firm or institution or technical publication, which specifies the industry sector, the period, the companies researched, and the profit margins and which identifies, for each company, the data collected and Regrettably, no example exists of a taxpayer successfully requesting a change in the margins. As a matter of fact, requesting such a change may be highly risky for the taxpayer, which must first execute transactions to be able to document them. This effectively eliminates the possibility that the taxpayer will be able to manage its transfer prices so that they remain within the prescribed margins during the fiscal year ation requirements regarding third parties(e.g, copies of fiscal documents given to consumers by other retailers in the country of destination of the items=)may easily be outside of the taxpayer,s access. Furthermore, there is no guarantee--or even evidence of the likelihood--of approval by the tax authorities Safe harbors Price Range Pursuant to the law, as long as the transfer price does not deviate from the parameter price found using one of the methods by more than 5 percent(over or under the parameter price), no adjustment occurs Safe Harbors on Exports Brazil also provides a transfer pricing safe harbor for companies whose net revenue from export transactions to related parties represents less than 5 percent of their entire net revenue. 2 Profitability Safe Harbor Alternatively, no special transfer pricing documentation for exports is necessary as long as an enterprise demonstrates its net income, before corporate income tax and social contributions, from export earnings to related parties is more than 5 percent of net revenue derived from these earnings For the purpose of this comparison, an average must be calculated that includes the fiscal year and the two preceding years. This means, however, that a net profit margin of over 5 percent in one year does not necessarily mean the taxpayer qualifies for the safe harbor. For instancecircumstances.25 Taxpayers or a class entity may request a change by demonstrating inter alia the whole annual effective buying and selling registers involved in the solicitation and its respective freight and insurances paid. The rules also require documentation that shows changes in rates. For this requirement, taxpayers may use publications and reports issued by the government of the seller's or purchaser's country, or a statement of that same country when Brazil and that country have entered into a convention for the avoidance of double taxation or an agreement for the exchange of information; or market research conducted by a recognized, technically qualified firm or institution or technical publication, which specifies the industry sector, the period, the companies researched, and the profit margins, and which identifies, for each company, the data collected and analyzed. Regrettably, no example exists of a taxpayer successfully requesting a change in the margins. As a matter of fact, requesting such a change may be highly risky for the taxpayer, which must first execute transactions to be able to document them. This effectively eliminates the possibility that the taxpayer will be able to manage its transfer prices so that they remain within the prescribed margins during the fiscal year. In addition, supplementary documentation requirements regarding third parties (e.g., copies of fiscal documents given to consumers by other retailers in the country of destination of the items26) may easily be outside of the taxpayer's access. Furthermore, there is no guarantee--or even evidence of the likelihood--of approval by the tax authorities. Safe Harbors Price Range Pursuant to the law, as long as the transfer price does not deviate from the parameter price found using one of the methods by more than 5 percent (over or under the parameter price), no adjustment occurs.27 Safe Harbors on Exports Brazil also provides a transfer pricing safe harbor for companies whose net revenue from export transactions to related parties represents less than 5 percent of their entire net revenue.28 Profitability Safe Harbor Alternatively, no special transfer pricing documentation for exports is necessary as long as an enterprise demonstrates its net income, before corporate income tax and social contributions, from export earnings to related parties is more than 5 percent of net revenue derived from these earnings.29 For the purpose of this comparison, an average must be calculated that includes the fiscal year and the two preceding years.30 This means, however, that a net profit margin of over 5 percent in one year does not necessarily mean the taxpayer qualifies for the safe harbor. For instance: