Realistically Available Options

Brazilian Legislation and OECD Determinations

Abstract

This article aims to explore the concept of realistically available options in the context of transfer pricing, highlighting the importance of analyzing OECD Guidelines and Brazilian legislation in assessing the compliance of existing options used in specific cases. The analysis demonstrates that for an option to be considered valid, it must align with the factual reality of the company at the time the decision was made. The study also discusses how non-compliance with these rules can invalidate the consideration of an option, affecting business decision-making.