§79. The international transactions envolves a lot of specific caractheristics. One of them is the difference between the methods of book value that can exist. This is why there is an international effort to find global standards of accountant principals. The IFRS (International Financial Reporting Standards) is exacly this: standarlization of accountant rules; observing that IFRS is the development of what before was the IAS (International Accounting Standard). For example, the IFRS 3 states that “an acquirer measures the cost of the acquisition at the fair value of the consideration paid; allocates that cost to the acquired identifiable assets and liabilities on the basis of their fair values; allocates the rest of the cost to goodwill; and recognises any excess of acquired assets and liabilities over the consideration paid (a ‘bargain purchase’) in profit or loss immediately. The acquirer discloses information that enables users to evaluate the nature and financial effects of the acquisition”.
§80. In the other hand, we have the BR GAAP (Generally Accepted Accounting Principles in Brazil), which one are stated, mainly, in the Law 6.404/1976, changed by the Law 11.638/2007. It is this law that defines, e.g., the subdivision of asset in permanent asset and current asset, being the permanent asset subdivided in fixed asset, intangible asset, etc. Also is part of this normative framework the Brazilian Accountant Norms (NBC), of the Brazilian Federal Accounting Council (CFC). For example, the NBC TG 46 (R2) is the norm that establishes the “fair value” as an amount resulted of a non forced transaction, with highest and best use, among other caractheristics. As a result of the CFC, Brazil also has the Brazilian Committee on Accounting Principles, that also states accounting pronouncements that works as rules in the sector aiming the convergence with the IFRS.
§81. What it is important have in mind is that the taxation fact is a result of how the world is measured by the accounting principles.
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