Two activities aimed at giving continuity to efforts initiated by the UN for controlling harmful transfer pricing manipulation, which has resulted in the publication of a manual, were held in Panama on December 10-12. It brought together participants from twelve (12) tax administrations from developing countries in Africa, the Americas and Asia, eight (8) experts from the academic, entrepreneurial and governmental areas, as well as a representative from ATAF. Both activities are part of the Program for Capacity Development within the sphere of International Tax Cooperation.

A course on the main legal and administrative aspects to be considered when controlling transfer prices was held on December 10. Its purpose was to level the rate of knowledge in order to prepare the discussions to be had the following days. On December 11 and 12, the experts presented and discussed with the participants the drafts of the course materials, which were based on modules II, III, VII and IX and the UN Transfer Pricing Manual. Likewise, a case study on “comparability analysis” and application of “transfer pricing methods” was presented and discussed in the next to the last session.

This activity is the result of a fruitful relationship between the UN and CIAT, which in recent years has allowed both institutions to develop and apply a tool for measuring tax transaction costs as well as to provide training in the sphere of double taxation treaties and the control of harmful transfer pricing manipulation.

Participants

Meeting table