Transfer pricing charged by the French and Brazilian companies between 1994 and 2010 : ‘intangible property rights case'
Transfer pricing are the prices to which services, the tangible property and intangibles are exchanged between parties with a link dependency in cross-border operations. The transfer pricing of the transactions with the intangible property rights adopted by a group of parties having a bond of dependence have a direct incidence on the benefit declared by each one as of these parts in their respective country. The French and Brazilian legislative measures incorporate the principle Řarms, however implicitly. The question of whether a taxpayer has respected the principle Řarms, however implicitly is a matter of fact to be examined in each case.