The globalization phenomenon, characterized by the increasing influence of international trade in the global economy, as well as the dominance of multinational companies in business flows and composition of the global gross domestic product, has brought new challenges for tax administrations.

Transfer prices are used to determine the taxable profits of international corporate groups that have branches in several countries. In some cases, these groups report all the costs in a country that has a high tax burden and report their sales in one that has a lower tax burden, with the aim of lowering their direct taxes and / or transfer profits to other regions with a lower tax burden or, in extreme cases, not taxation.

In tax administrations, transfer pricing enable to review and challenge the valuation of goods and services as established in transactions between related parties.

Because of the importance of transfer pricing for tax administrations, the Inter-American Center of Tax Administrations has drafted the Transfer Pricing Course, consisting of three modules: Theoretical Aspects, Practical Aspects and Advanced aspects.

In order to keep the course updated with the latest practices in transfer pricing, during the week from 23 to 27 November, 2015, a workshop organized by CIAT and sponsored by the German Cooperation GIZ was held in Panama City, Panama.

Tutors Alfredo Sosa (Argentina), Oscar Ramos (Argentina), Solange Lizewski (Argentina), and Jose Luis Galindez (Venezuela) attended the workshop; as well as experts Felipe Flores and Jessica Manzo Chile Lisandro Manuel Junco Riveira of Colombia, Jairo A. Godoy G of Ecuador, Omar Mendoza Ramirez of Mexico, Karina Egoavil Gisella Mendoza of Peru, Marcia Grostein Orzuj of Uruguay.

The students with the best qualifications were also invited: Iris Torres Town (Costa Rica), Roberto Enrique Hernandez Sanchez (El Salvador), Evelyn Cooban (Panama), Albertina Méndez Burgos (Dominican Rep.) And Andrés Alberti (Uruguay).

The workshop exceeded its goals and expectations as rich debates were generated during the case studies analysis, and the various transfer-pricing methods used by Latin American countries were presented.

As part of the workshop conclusions, it was decided to change the order of topics covered in the course, modify the methodology used in the forums, adopt a more friendly language, add more mini cases and unify the three modules to provide a single course with a duration of approximately 15 to 20 weeks.

In addition, it was suggested to offer short term (2 or 3 weeks) online forums with specific topics (sixth method, APAs, commodities, intangibles) to the officials of our member countries tax administrations who have completed the transfer-pricing course.

Group photo

From left to right:: Mr. Alejandro Juárez, Training & Development of Human Talent Directorate of CIAT, Mr. Márcio Ferreira Verdi,CIAT Executive Secretary,, Mr. Públio Cortés, Director General of Revenue of the Panama andl Mr. Oscar Ramos, Tutor and CIAT Consultant.

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