a huge administration procedure for the taxpayer, who must manage the immense volume of transactions. Exacerbating the situation is the fact that Brazil does not allow aggregation of transactions or limit application of its equirements to only the most relevant transactions. Controversies regarding the rules'contents are vivid problems Law 9. 430/97 describes transfer pricing methods, divides transactions into imports and exports, and offers approaches for each. For each approach, the law describes a limited number of methods applicable to each product, service, or right Import Transaction Methods Method of Compared Independent Prices Since no other methods consider the comparison of prices adopted between non-related enterprises, the Method of Compared Independent Prices(PIC) is the only Brazilian method available that applies the arm s -length principle in This method is defined as the arithmetic mean of prices of goods, services and rights equivalent or similar to goods, services and rights selected within the Brazilian market or in other countries in purchase and sale operations under similar payment conditions. The price of imported goods, services, and rights purchased from a related party must be compared with the prices of equivalent or similar goods, services, and rights. This may be done through n internal or through an external comparison Price adjustments to minimize the effects of differences in the business conditions, physical nature and contents on the prices to be compared may be done as long as they are strictly related to e liability for product warranty or for the applicability of the service o liability for promotion of the goods, services, or rights to the public by means of advertising and publicis Q liability for quality control, service, and sanitary standards o agency costs for purchase and sale transactions carried out by unrelated parties, taken into account for the purpose of price freight and insular In this sense, rather than a potentially wide adjustment based on functionsa huge administration procedure for the taxpayer, who must manage the immense volume of transactions. Exacerbating the situation is the fact that Brazil does not allow aggregation of transactions or limit application of its requirements to only the most relevant transactions. Controversies regarding the rules' contents are vivid problems. Law 9.430/97 describes transfer pricing methods, divides transactions into imports and exports, and offers approaches for each. For each approach, the law describes a limited number of methods applicable to each product, service, or right. Import Transaction Methods Method of Compared Independent Prices Since no other methods consider the comparison of prices adopted between non-related enterprises, the Method of Compared Independent Prices (PIC) 6 is the only Brazilian method available that applies the arm's-length principle in import situations. This method is defined as the arithmetic mean of prices of goods, services, and rights equivalent or similar to goods, services and rights selected within the Brazilian market or in other countries in purchase and sale operations under similar payment conditions. The price of imported goods, services, and rights purchased from a related party must be compared with the prices of equivalent or similar goods, services, and rights. This may be done through an internal or through an external comparison. Price adjustments to minimize the effects of differences in the business conditions, physical nature and contents on the prices to be compared may be done as long as they are strictly related to: payment terms; negotiated volumes; liability for product warranty or for the applicability of the service or right; liability for promotion of the goods, services, or rights to the public by means of advertising and publicity; liability for quality control, service, and sanitary standards; agency costs for purchase and sale transactions carried out by unrelated parties, taken into account for the purpose of price comparisons; packaging; and freight and insurance. In this sense, rather than a potentially wide adjustment based on functions