Mapping of Controlled Operations: Identification and documentation of controlled transactions, functions performed, assets used and risks assumed.

Selection and Justification of Methods: Selection and justification of the most appropriate calculation method for each controlled transaction.

Comparability Analysis: Identification and analysis of internal and external comparables, including necessary comparability adjustments.

Documentation of the Group Structure: Preparation of a detailed organizational chart of the multinational group, including a description of activities, supply chains and financial operations.

Documentation on intangibles: Collecting and analyzing information on intangible assets that impact the group's profitability.

Consolidated Financial Statements: Compilation and review of the multinational group's consolidated financial statements.

Completion of TXT files: Assistance in preparing the TXT files required for the ECF, including details of transactions, parameter prices, methods applied and transfer pricing adjustments.

Data validation: Verification and validation of the data to be submitted, ensuring compliance with Receita Federal requirements.

Development of Global Policies: Creation and implementation of transfer pricing policies that meet the requirements of the new legislation, including the strategy for adjusting controlled operations.

Proactive Tax Adjustments: Identification of potential tax adjustments and advice on best practices for risk mitigation.

Training Programs: Development of customized training programs for the client's team, covering everything from the basics of transfer pricing to the specifics of the new legal regulations.

Practical Workshops: Practical workshops to demonstrate the application of transfer pricing methodologies and the preparation of the required documentation.

Update Sessions: Regular update sessions on regulatory changes and best practices in transfer pricing.

Assistance with audits: Support in preparing documentation and responses for audits conducted by the Internal Revenue Service.

Defense of positions: Assistance in defending the transfer pricing policies adopted by the company in administrative or judicial proceedings.

CUP method for commodities: Application of the comparable price method for commodities, in accordance with the new guidelines, adjusting for factors such as logistics costs and market premiums.

Valuation of financial transactions: Analysis and documentation of financial transactions, such as intercompany loans and guarantees, in accordance with the new transfer pricing rules.

Identification of adjustment needs: Evaluation of operations to identify possible needs for compensatory or spontaneous adjustments.

Documentation and implementation of adjustments: Support in the documentation and implementation of these adjustments, ensuring that they are carried out in accordance with the established guidelines.