UN-CIAT Course on Transfer Pricing

In line with the continued efforts initiated by the United Nations in strengthening capacity of developing countries in the area of transfer pricing, the Financing for Development Office (FfDO) in collaboration with the Inter-American Center of tax administrations (CIAT) have organized the United Nations Course on Transfer Pricing, based on the UN Practical Manual on Transfer Pricing for Developing Countries. This course was offered for the benefit of tax officials from countries of Latin America and the Caribbean working in this field, introducing them to the fundamentals of transfer pricing. The course was held in Panama City, from 24 to 28 August 2015. The participants included 37 officials from 19 countries members of CIAT.

The UN was represented by Mr. Harry Tonino, and Mrs. Irving Ojeda; and Mr. Márcio F. Verdi and Mr. Alejandro Juárez participated for the CIAT.

This course aims to introduce the principles and methodologies of transfer pricing and presents the main practical aspects faced by developing countries in implementing these principles and methodologies. Some of the topics discussed during these five days were: the business framework and legal environment; the arm’s length principle; the analysis of comparability; transfer pricing methods; documentation; risk assessment; disputes prevention and settlement; and capacity building for the enforcement of transfer pricing in developing countries. In addition, several examples were developed and two practical cases allowed participants to put into practice the knowledge acquired during the course.

The course was presented by Mr. Joseph Andrus, Mr. Giammarco Cottani, Ms. Monique van Herksen and Mr. José Madariaga.

This activity was the result of a fruitful partnership between UN and CIAT, which in recent years has allowed both institutions to develop training in the field of treaties to avoid double taxation and transfer pricing.

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Presentations during the event.

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The experts, from left to right: Joseph Andrus, Giammarco Cottani, Monique van Herksen y José Madariaga.

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From left to right: Joseph Andrus, Giammarco Cottani, Monique van Herksen, José Madariaga, Irving Ojeda y Harry Tonino.

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Official photo of the event.

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