The analysis of transfer prices for tax purposes is based on the Arm’s Length principle. This principle establishes that taxpayers of this control regime are obliged to value their transactions as if they were independent entities in comparable circumstances. Most tax legislations and agreement to avoid double taxation in Latin…
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The recent June 2017 OECD meeting on the Inclusive Framework on BEPS had a large turnout of participating countries, international organizations and other entities. It’s evident that this initiative has major acceptance by almost all jurisdictions. As the name implies, these bi-annual meetings primarily address subjects related to the OECD/G20…
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The current process for reorganizing the international tax system has been focused on avoiding the erosion of the taxpayers’ tax base, thereby originating the ambitious action plan derived from the document issued by the Organization for Economic Cooperation and Development (OECD) entitled: Addressing BEPS (Base Erosion and Profit Shifting). The…
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The No. 42 edition of the CIAT/AEAT/IEF Tax Administration Review of June 2017 includes an article by Ignacio González, from the Spanish Tax Agency, which deals with tax control issues in the digital economy. I recommend that it be read, especially segments 3 and 4, which give an idea of…
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The implementation of the electronic invoice, in the way that has been done successfully in Latin America, is effective when there is a valid invoice standard at national level. The tax administration should have all the documents and the majority of documents are signed digitally or, at least, generated in…
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At the last CIAT General Assembly, held a little over a month ago in Asunción, I was asked to reflect on these “deceptively” simple questions. How to respond, briefly, to questions that lead us to consider what is or what should be the “tax model“? And how to do it…
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