In the collaboration framework between CIAT and GIZ from Germany, on October 29 to 31 of the current year, a study visit to SAT of Mexico took place, with the purpose of benefitting from SAT’s wide experience in the field of controlling the abusive manipulation of transfer pricing.

In the past three years, we have seen significant progress by several Latin American countries. These countries have not only implemented and adjusted standards to regulate transfer pricing, but have also implemented administrative structures and processes enabling to achieve good results in the control field.

This cooperation action aimed to follow the aforementioned evolution that several Latin American countries have achieved in the area and which is complemented with other efforts made in recent years by CIAT’s Executive Secretariat within the scope of the EUROsociAL Program, GIZ from Germany and the “International Tax Compact”.

This action was carried out with the participation of officials of the international control areas from the tax administrations of Ecuador, Peru, Uruguay, Costa Rica, Colombia, Chile and Guatemala.

Among the main issues that were discussed are the aspects relating to the planning of transfer pricing audit processes, the functional and economic analysis, the selection of the appropriate method, the identification of comparable transactions, the intra-group services, intangibles, the exchange of information between States, the negotiation and management of APA-BAPA-MAP, the agreements to avoid double taxation and some relevant court rulings.

Event’s official photo.