It is now well-known that many developing countries are faced with major losses arising from their inability to tax the economic activities and value creation generated within their borders by multinational enterprises (MNEs). The losses arise from a variety of causes, including aggressive tax planning by some MNEs. Tax administrations…
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The Gartner Hype[i] Cycle provides a graphic representation of the maturity and adoption of technologies and applications, which in addition to having relevant potential for solving institutional problems, allow for anticipating new opportunities. This methodology affords an overview of how a technology or application will evolve through time, thereby providing…
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I wrote this post “And yet“ nearly three years ago, warning that it was unnecessary because we are all convinced of the importance of data quality, and we all act accordingly. However, today again comes to my mind this quote from H. L. Mencken, telling us “For every complex problem…
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The United Nations (UN)’ Handbook on Extractives Industries Taxation identified important tax issues in the extractive industries, including the indirect transfer of assets, permanent establishment issues and transfer mispricing risks. However, the handbook fell short of addressing how beneficial ownership and project-level reporting disclosure can help address concerns on these…
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Issuing reports as a result of the work of the BEPS Action Plan resulted in a major update of the OECD Guidelines applicable to transfer pricing for multinational enterprises and tax administrations (“OECD Guidelines”) in 2017. The different jurisdictions in Latin America have focused efforts in adapting their regulations to…
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The purpose of sharing these thoughts with you is to analyze some trends in the control function of the Tax Administrations (TAs) to answer the question of what kind of controls should be currently prioritized. Currently, it means determining if they must be massive, extensive, or otherwise intensive or deeps…
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