CSRF UNDERSTANDS THAT THE CONCEPT OF WHOLESALE MARKET PRICE IS
NOT RESTRICTED TO MARKETS LOCATED IN A MUNICIPALITY, BUT ALSO TO
METROPOLITAN REGIONS
The 3rd Panel of the Superior Chamber of Tax Appeals - CSRF
innovated in a recent judgment that analyzed the concept of
‘wholesale market price’ which is used as reference to
obtain the Minimum Taxable Value (VTM) in the tax basis of the Tax
on Industrialized Products – IPI in operations between
related companies. According to art. 195 of the IPI Regulations
(RIPI), the VTM in such cases cannot be lower than the regular
wholesale market price applicable in the municipality of the
sender.
The case analyzed by the CSRF involved a cosmetics company that
had its factory in a large industrial center and sent its finished
products to a wholesale distributor located outside the city, where
wholesale market prices are usually lower.
