The CIAT Executive Secretariat is pleased to provide hereby the latest update of the “Analysis of the legal framework for the control of transfer pricing in Latin America” report, prepared by the International Cooperation Management Office with the valuable support of officials from the tax administrations of Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, El Salvador, Guatemala, Mexico, Panama, Peru, Uruguay and Venezuela.

The objective of the aforementioned report is to make known, in a relatively simple and schematic manner, the provisions for the control of existing transfer prices in the Latin American countries. Accordingly, in order to simplify the analysis and comparability of the information, it is possible that all of the information included in the legal provisions is not available for certain aspects considered in the report. For this reason, the criterion adopted was to identify a series of aspects considered critical for analyzing each of the legislations, to then determine whether those aspects were totally or partially, explicitly or implicitly considered considered in the text of the regulation.

The aspects dealt with in the report are the following:

– Differences in corporate income tax rates in the Central American, Mercosur and Andean   Community countries.

– Evolution of legislations through time for controlling the manipulation of transfer prices in Latin America

– Drafts, projects and reforms in the process of elaboration or discussion in Latin America

– Individuals and operations subject to the transfer pricing systems

– Related party concept

– Methods for determining transfer prices

– Criterion for determining the hierarchy of the methods

– “Safe Harbors” in Latin America

– Advance Pricing Agreements in Latin America

– Adoption of official reports for interpretation purposes or as a complement to legal provisions.

– Information systems

– Specific sanctions for formal or significant noncompliances within the framework of international operations

– Structures adopted by the tax administrations of Latin America for controlling the manipulation of transfer prices or international operations… Complete Information

View report “Analysis of the legal framework for the control of transfer pricing in Latin America”