It is a pleasure to inform you that section 3.12 of the new Manual for the Control of International Tax Planning, entitled “Payments for technical assistance, royalties, interest, dividends and services”, is now available. The authors of this section, Fernando Becerra O’Phelan and Giovanni Cerrón López, analyze the main risks to be taken into account when verifying these types of transactions, making use of practical examples for a better understanding. These examples focus on selected cases classified as high-risk for tax purposes, such as back-to-back loans and business restructurings, amongst others.

We believe that this section will be useful to understand the problems raised by Actions 3 and 8 of the OECD BEPS Action Plan, and for those who intend to reinforce those regulations that impact the control of passive income streams, transparent companies and intra-group payments.

Section 3.12 is available in English and Spanish and is the fifth document published within the framework of the Manual for the Control of International Tax Planning, brought to you by CIAT-GIZ-EUROsociAL+. The complete Manual has 6 chapters made up of 42 sections, more sections will be published soon.

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