Comentários ao Processo nº 16327.000924/2003-14 do CARF
| Autor | Pontieri |
“PREÇOS DE TRANSFERÊNCIA. MÉTODO PRL. BENS IMPORTADOS APLICADOS NA PRODUÇÃO DE OUTROS BENS. A Lei 9.430/96 facultou à pessoa jurídica a utilização de qualquer um dos três métodos legalmente previstos — PIC, PRL e CPL — para determinação dos preços-parâmetro nas operações de importação de bens, serviços e direitos de pessoa vinculada. O art. 40, § 1 0, da IN SRF n° 38/97, ao vedar a utilização do método PRL nos casos de bens importados aplicados na produção de outros bens, ultrapassou o seu limite de regulação, impondo restrição não prevista na lei.
Assunto: Imposto sobre a Renda de Pessoa Jurídica - IRPJ
Ano-calendário: 1999
Ementa: PREÇOS DE TRANSFERÊNCIA. MÉTODO PRL. APURAÇÃO DE MARGEM DE LUCRO POR PACOTE, KIT OU CESTA DE BENS (BASKET A PPROACH). A comercialização de bens por pacotes ou kits, adotada tão-somente como estratégia de mercado, sem qualquer necessidade técnica imprescindível de uso dos bens conjuntamente, não autoriza a utilização da margem de lucro do pacote de bens (basket approach) para fins de apuração do valor tributável na sistemática de preços de transferência pelo método PRL.
Assunto: Imposto sobre a Renda de Pessoa Jurídica - IRPJ
Ano-calendário: 1999
Ementa: PREÇOS DE TRANSFERÊNCIA. MÉTODO...
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