Data base on transfer pricing rules and practices in Latin American and Caribbean countries

Thanks to the contributions of 25 tax administrations from Latin American and Caribbean countries, the CIAT Executive Secretariat makes available to the international tax community, this Database on transfer pricing rules and practices, updated between January to October, 2021.

In case users may have observations or questions regarding the information in this Data Base, please contact Mr. Isaác G. Arias E., International Cooperation and Taxation Director (garias@ciat.org), Ms. Anarella Calderoni (acalderoni@ciat.org) and Mrs. Pamela González (pgonzalez@ciat.org).

General Section

Update by country

1. General Regulatory Aspects

2. Related Parties

3. Formal Obligations and Documentation

4. Sanctioning System

5. Transfer Pricing Analysis

6. Most Used Methods

7. Interest rates

8. Correlative, Secondary and Self Adjustments

9. General TP control measures

10. General Audit Information

11. Judicial Aspects

12. Aspects of the International Tax Team

13. Exchange of Information for Tax Purposes

14. Advanced Pricing Agreements

15. Sources of Information for TP Control

16. Anti Abuse Rules

17. Safe Harbour

18. Tax Havens

Sixth Method

1. Regulations

2. Legal nature of the measure

3. Arm’s Length Principle

4. Design of the measure

5. Characteristics of the reference markets for the application of the measure

6. Economic sectors in which the measure is applied

7. Adjustments applicable for the application of the measure

8. Main challenges detected when applying the “sixth method”

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