The Internal Revenue Service of Chile (SII) together with the Inter-American Center of Tax Administrations (CIAT) and the German International Cooperation Agency (GIZ) held a regional exchange seminar on the control of large businesses and transfer pricing in Santiago de Chile on October 8-10, 2013.

The participants in this activity were specialized officials from the tax administrations of Brazil, Colombia, Costa Rica, El Salvador, Ecuador, Mexico, Nicaragua, Peru and Uruguay.

The results and benefits of the study on access to information of tax interest in the Latin American countries, as well as possible strategies for advancing in developing coordination mechanisms to facilitate access to this type of information were presented during the course of the seminar. Thereafter, the representatives of the tax administrations of Colombia, Mexico and Chile presented actual cases involving risks of abusive manipulation of transfer pricing. These were analyzed by the participants, in order to familiarize themselves with best practices, identify situations wherein the treasury could have acted differently and also to comment on the differences in practice and legislation.

A third panel formed by tax consultants from the “big four” as well as local firms, presented their views on the recent Chilean tax reform. In an active and productive discussion the panel considered the regulations regarding the abusive transfer pricing manipulation, aspects dealing with information systems and the relationship of large businesses with their tax consultants and the treasury.

Upon conclusion of the seminar, working groups were set up for analyzing the current context and determining possible initiatives which could be undertaken by CIAT with cooperation from the GIZ, for promoting the exchange between tax administrations and strengthening their capabilities. It has been confirmed that there is a great interest in continuing to strengthen the large taxpayer units, particularly in relation to transfer pricing and information exchange.

Group photo		Deputy Finance Minister, Julio Dittborn		Speaker: Alejandro Burr, Director (SII) Service of Internal Taxes. Table: From left to right, Claudio Salcedo (Salcedo and Cía), Tyriak Bruzual (E&Y), Rocío Crespillo (Deloitte), Roberto Rivas (PricewaterhouseCoopers)
Jörg Wisner, Germany’s GIZ		Participants		Speaker: Gonzalo Arias, CIAT’s Director of Cooperation and International Taxation. Table: from left to right, Claudio Salcedo (Salcedo y Cía.), Tyriak Bruzual (E&Y), Rocío Crespillo (Deloitte), Roberto Rivas (PricewaterhouseCoopers) and Juan Pablo Guerrero (KPMG)