transfer pricing in brazil- definition of related party?

Question

A (USA) company sell CKD materials to B comapny (Contract manufacture located in Brazil). B company manufacture and then sell the finished goods to C company (brazilian company). A company and C company have the same parent company, but both have no relationship with B company . Based on Brazil TP rule, should C company need to do transfer pricing adjustment for this kind of transaction? If C company insist it's not related party transaction and don't do any TP adjustment, does it comply with Brazil TP rule?

Answer 1

Even if it's wrong , what can you do about it in Brazil?