A study visit to the Tax Administration Service of Mexico was carried out in the City of Mexico from November 14th to 16th, 2011, oriented to offer the experience in the matter of control of the abusive manipulation of transfer pricing.

This visit has been possible as a result of the integration of efforts by GIZ of Germany and CIAT, and the good predisposition of the SAT of Mexico whose experts have demonstrated high levels of knowledge and dedication to public service.

Officials from the transfer pricing areas and from the control of large companies of the Tax Administrations of Colombia, Ecuador, El Salvador, Panama, Peru, Uruguay and Venezuela attended this activity, also, the CIAT International Cooperation Manager and the Director of the GIZ Programs of Germany.

The working hours have been intense and of high added value, a variety of complex subjects have been approached, such as: the planning of the stages of a process of transfer pricing audit; the functional and economic analysis; the selection of the appropriate method; the identification of comparable transactions; the technical adjustments; the intragroup services and intangible goods; the management of APAs, BAPAs, MAPAs; the application of the Agreements to avoid the Double Taxation and the analysis of judicial sentences on Transfer Pricing.

Due to the success, CIAT and GIZ have considered to stimulate this type of cooperation modality by virtue of the contribution that is offered for the optimization of the routine tasks of the officials from the beneficiary Tax Administrations and the feedback obtained by the Tax Administration that makes available its technical knowledge and experiences.

From left to right, Gonzalo Arias (CIAT), Luis Natera, Rosario Ramos (El Salvador).		Participants from Colombia, Ecuador, El Salvador, Panama, Peru, Uruguay and Venezuela took part to intensive workdays.
Delegates from the various Tax Administrations and organizations gathered at the SAT of Mexico.