Latin American countries are paying close attention to BEPS,
leading to changes in their local regulations or approaches to
audits related to transfer pricing. It is clear that MNEs
should be prepared to face more scrutiny regarding transfer
pricing throughout the region. In turn, the tax authorities are
in most countries increasing their documentation requirements
as well as the number of audits they are conducting.
Based on the above, companies will need to react quickly to
this new environment by establishing a specific strategy for
the region. To achieve that goal, regional documentation from a
centralised perspective and consistency with global policies
will be crucial.
This article aims to highlight the most relevant aspects of
each country and remark the recent key developments affecting
those doing business in each Latin American jurisdiction.
Topics include base erosion and profit shifting (BEPS)
developments, exchange of information and transfer pricing
In recent years, the OECD has been developing several
initiatives to avoid aggressive tax planning with the objective
of achieving double non-taxation or shifting income to
In this context, on June 7 2017, Argentina signed the
Multilateral Convention to Implement Tax Treaty Related
Measures to Prevent Base Erosion and Profit Shifting (MLI). The
MLI will strengthen provisions to resolve treaty disputes,
including through mandatory binding arbitration, thereby
reducing double taxation and increasing tax certainty.
With the MLI, the OECD embodied the BEPS principles that can
be automatically applied, under certain conditions, to the
bilateral tax treaties that have been executed by the different
signing countries among themselves.
The MLI provides a system to implement the recommendations
that arose from the BEPS project in relation to the previously
signed treaties. The MLI emphasises matters such as hybrid
instruments, tax abuse, permanent establishment status evasion
and improvement in conflict resolution and arbitrage
The MLI represents a major progress in the international
context of abusive tax-planning prevention. Nonetheless, it is
up to each jurisdiction to analyse in a cautious fashion every
single case to precipitously avoid each anti-evasion measure or
deny arbitrarily relevant tax benefits.
The method to be put in force by the signing parties, and
the possibility to determine between different forms of rules
over other forms, for example regarding treaty abuse, is an
original theme set forth in the MLI.
It should be pointed out that the MLI represents a paradigm
shift with respect to previous treaties, since it allows
modifying existing treaties without the need to initiate
bilateral negotiations with each of the counterparts,
implementing almost immediately the BEPS directives in
Argentina's treaty network. In addition, the BEPS agenda will
remain a priority during the Argentine presidency of the G20 in
In line with the above, tax avoidance involving tax treaties
has received attention in Argentina. In 2011, an Argentine
government commission reviewed the country's tax treaty network
to determine whether there was potential for abuse. The
following year, Argentina unilaterally terminated its tax
treaties with Switzerland, Spain and Chile, mainly to eliminate
the Argentine wealth tax exemption and to address perceived
potential for abuse regarding withholding taxes on royalties,
inappropriate use of conduit companies and other areas,
depending on the treaty.
Argentina recently signed new treaties with the following
- Spain (in force retroactively as of
January 1 2013);
- Switzerland (in force as of January 1 2015
for withholding taxes and January 1 2016 for other articles
and Article 25);
- Chile (in force as of January 1
- Mexico (in force as of January 1
In addition, on July 21 2017, authorities from Argentina and
Brazil signed the Amendment Protocol to the Treaty to Avoid
Double Taxation and Avoid Tax Evasion regarding taxation over
Most of the treaties signed by Argentina follow the model
proposed by the OECD. In the case of Brazil, the treaty was a
combination of different models, adjusted to each country's
In addition to eliminating the potential for abuse, these
treaties incorporate the current international standards on the
automatic exchange of tax information.
From another perspective, it is worth pointing out that
multinationals in Argentina have faced increasing audit
activity from the tax authorities regarding international
transactions. The local tax authority, AFIP, focuses on
specific industries. Transfer pricing and thin capitalisation
transactions have attracted particular scrutiny.
Argentine tax authorities are becoming more interested in
and have been challenging transactions and structures based on
the principle of substance over form. This principle is
included in Argentina's Tax Procedural Act, and the Argentine
tax authorities apply it broadly to disregard legal forms which
are not in sync with the intention of the parties involved in a
Given the Argentine tax authorities' focus on substance over
form, foreign companies doing business in the country should
make sure to have a sound, well-documented business purpose for
their business structures and transactions. In many tax
disputes ruled by the Supreme Court, taxpayers have received
favorable sentences when they were able to demonstrate the
business soundness and substance of their transactions.
As a final point, the tax authorities have stated publicly
that they are considering enacting legislation implementing
country-by-country (CbC) reporting. The legislation is expected
to adopt the master file requirement. Current legislation
already requires the filing of the local file on a yearly
basis. No effective date has been announced, but more
regulatory requirements and exchange of information regimes are
to be expected in the future.
The draft decree published by the Ministry of Finance and
Public Credit on August 11 2017 is intended to modify the
articles of Chapters 1, 2, 3 and 4 of Title 2 of Part 2 and
Chapter 1 of Title 3 of Part 6 of Book 1 of the Single
Regulatory Decree on Tax Matters, derived from the amendments
introduced by Law 1819/2016 to the TP regime.
The main changes established in the draft regulatory decree
are the following:
New limits (amounts) to TP documentation
The local report and the master file must be prepared and
submitted for those types of operations – intercompany
transactions with foreign related parties and/or located in a
free trade zone within the Colombian territory, or individuals
or entities in tax havens – for which the annual
amount is equal to or greater than 45,000 UVT ($450,000) of the
taxable year subject to documentation. It applies, as long as
the taxpayer's total assets or gross income exceeds the minimum
amount of 100,000 UVT or 61,000 UVT, respectively. In addition,
for those transactions carried out with persons, entities or
companies located, resident or domiciled in non-cooperating
jurisdictions of low or zero taxation or preferential tax
regimes, the local report and the master file should be
prepared and submitted for those types of transactions for
which the annual cumulative amount is equal to or greater than
10,000 UVT of the taxable year subject to documentation,
regardless of the amount of the total assets or gross income of
the taxpayer. The transactions that were considered as
non-deductible for income tax purposes and modified the results
of the income statement should not be analysed, but must be
mentioned as part of the taxpayer's TP documentation.
Master file – preparation and submission
The obligation to prepare and submit the master file starts
for the fiscal year 2017 for those taxpayers of income tax and
complementary taxes that exceed the limits mentioned above.
The draft decree includes – for analysis and
comments of third parties – a detailed list of the
suggested information to prepare the master file. It should
incorporate a global vision of the multinational group
including its organisational structure, business description,
intangibles, financial activities, and financial and tax
CbC report – preparation and submission
For this obligation, which applies for the fiscal year 2016,
the draft decree includes a detailed description of the
information that the CbC report must contain in order to comply
with the assumptions indicated in Article 2 of 260-5 of the
Colombian Tax Statute. In general terms, it must contain the
following information for each of the jurisdictions in which
the multinational group operates: consolidated revenues, profit
or loss before income taxes, income tax paid and accrued,
stated capital, accumulated earnings, number of employees and
tangible assets other than cash and cash equivalents.
Commodities – TP analysis
The decree for discussion states that the comparable
uncontrolled price method should be applied to determine the
arm's-length condition of the transactions related with
commodities. In this sense, the dates and/or specific periods
agreed by the parties for the determination of the price of the
commodities must be demonstrated by reliable documents,
supporting that they were consistent with what would have been
agreed by independent parties in comparable circumstances, and
registered in the electronic means developed by the Colombian
Finally, it is important to mention that the Ministry of
Finance and Public Credit established August 25 2017 as the
deadline for comments and/or observations to the Draft
With the publication of the ruling DGT-R-16-2017, Costa Rica
introduced important changes to its TP rules. The local file
must now include more detailed information than before, aligned
with the requirements of the OECD's BEPS Action 13. Costa Rica
has also introduced the obligation of the master file,
beginning the fiscal year of 2017. The master file must be
delivered to the tax administration upon request and the
content of the report is the same as established in BEPS Action
13. No CbC rules have been discussed or implemented yet.
In addition, Costa Rica's tax administration has suspended
the transfer pricing informative return filing until further
Under the transfer pricing regime in Ecuador, the advanced
transfer pricing assessment (ATPA) is applicable. In this
regard, the Ecuadorian tax code establishes that income tax
payers who have performed transactions with their related
parties and who are subject to the transfer pricing regime must
file an ATPA with the tax authority with respect to the
valuation of transactions performed between them and their
related parties. These are the requirements:
- General information of the taxpayer
submitting the ATPA, as well as details of the transactions
to be valued under the ATPA.
- Information on the related parties and the
agreements that the tested party has signed with them.
- Preliminary valuation of the transactions
and methodology according to the arm's-length principle under
Ecuadorian tax regulations.
- Relevant assumptions: The taxpayer should
indicate the relevant information used, referring to the
facts or circumstances that affected or could affect the
economic valuation of the transactions included in the
The tax authority may request at any time that the taxpayer
as well as third parties provide any additional information
which may be considered necessary, for instance reports,
background and justifications related to the proposal, as well
as additional explanations or clarifications about the
Within two years from the date of submitting the ATPA, the
tax authority will issue a resolution either accepting or
rejecting the assessment performed by the taxpayer. If the
resolution is approved the taxpayer may apply it for three
If the ATPA is approved by the Internal Revenue Services,
taxpayers are not required to file a transfer pricing report
and appendices with respect to transactions covered by the ATPA
for three years.
Within two months of the effective date of the income tax
report for each period in which the resolution is valid,
taxpayers must submit a report related to compliance with the
conditions included in the ATPA. The report must include the
- Operations carried out in the tax period
to which the methodology has been applied.
- Prices, amounts of compensations, or
profit margins of such operations as a consequence of
applying the methodology.
- Description of the behavior of the
circumstances referred by the critical assumptions
established in the methodology and justification of
compliance with such assumptions.
- Description of the application of the
methodology to the results of the fiscal year.
The new Honduras tax code introduced small changes to the
country's TP rules, with the most important discussing
transactions subject to analysis. Transactions between local
related parties are no longer required to be reviewed, unless
one of the related parties is part of a free trade zone or any
other tax benefit regime.
In general terms, TP rules in Honduras are based on the OECD
guidelines and methods, and so far, no rules for CbC reports or
master files have been discussed or implemented.
According to Law 822, TP rules are applicable as of June 30
2017. Nicaragua's TP rules are based on the OECD guidelines and
methods. No TP law has been published yet, but important topics
such as materiality, arm's-length range and comparable year
data are waiting to be clarified by the tax administration.
Nevertheless, the first year of application of the TP rules is
still fiscal year 2017.
Also beginning fiscal year 2017, the master file can be
requested by the tax administration. Local requirements for the
master file are limited in scope, but a report based on the
OECD's BEPS Action 13 can be made and delivered to the tax
administration upon request. No CbC rules have been discussed
or implemented yet.
There have not been any changes to the current TP
regulations since the last reforms in 2014. In the last fiscal
year, the tax administration promoted a draft reform of the tax
code, but to date, it has not been approved, and not many
believe that the TP regulations will be reformed in the short
During the last year, the tax administration has increased
its auditing processes in transfer pricing, evaluating in
detail the support documentation for intercompany transactions
(TP report) and focusing on the materialisation of services.
The audit procedures are mainly focused on the largest
taxpayers, regardless of industry.
Regarding the new OECD guidelines and the OECD's BEPS
project, the tax administration has not announced any draft
reform to the tax code that includes such recommendations. To
date, there are no new guidelines and/or documentation
requirements on TP issues. Neither has the tax administration
given notice on the implementation of the CbC report.
Although our local legislation makes a link to the OECD
guidelines, it will be important for the tax administration to
inform taxpayers if this link is absolute to all requirements
set out in the new guidelines or which of these new provisions
will be adopted for the practice of transfer pricing in the
local territory; considering that El Salvador, to date, is not
a member country of the OECD.
Most recent developments in Guatemala in the transfer
pricing area revolve around transfer pricing documentation,
information and TP audits.
In late 2016, the tax administration, SAT, published its
Transfer Pricing Technical Guide in order to standardise the
content and analysis of the TP report. This guide is completely
aligned with the OECD's BEPS Action 13.
In early 2017, the SAT modified the transfer pricing
informative return that taxpayers need to file jointly with
their income tax return. The high level and depth of the
information required made it necessary for taxpayers to
actually have the 2016 transfer pricing study completed at
hand. This behaviour by the SAT implies the need to have the TP
studies completed no later than March 31 of each subsequent
In 2016, the SAT started TP audits with respect to the 2013
fiscal year. The more significant assessments made by the tax
authority were in respect to transactions of trade of
commodities where the SAT is objecting import and export
related prices on a transaction-by-transaction basis rather
than accepting a global analysis based on an arm's-length range
for the fiscal year, and also the use of comparable companies
reporting losses. Taxpayers are now discussing these
assessments and they are expected to escalate to judiciary
In October 2016, Panama announced it was incorporating the
OECD's BEPS rules, and has started to make some changes to TP
Executive Decree No. 390 was enacted, which modifies the
regulation of the arm's-length principle, effective as of
January 1 2017. Among the most relevant changes, we can
highlight the following.
It is ratified that transactions with related parties must
be analysed one transaction at a time and according to the
valuation methods established in article 762-F of the tax code.
On this point, two or more transactions may be grouped for the
purpose of their analysis, when they are cohesive from an
economic point of view or one is a continuation of the other,
making it impossible to separate them.
It is emphasised that the use of financial information from
multiple periods can only be used when it adds value to the TP
analysis. Furthermore, it states that multi-year data of
relevant economic cycle information and the life cycle of
comparable products can be used when these facts and
circumstances improve reliability.
It is noted from its wording that it is not yet clear
whether the taxpayer can use the financial information from
multiple years for its economic analysis. During transfer
pricing audits the local tax authority pointed out that the
only period to be used is the one that coincides with the
taxable income, alleging that with this procedure it will be
clear to which period a possible transfer pricing adjustment
It is emphasised that comparable Panamanian companies will
have priority over comparable international ones. The
information available on comparable companies located in other
countries may be used, provided it complies with the comparable
analysis established in the tax code and its regulations. For
this purpose, the taxpayer must justify its selection, as well
as its search efforts for potentially comparable companies, the
date and their source.
The information and documentation requirements of the TP
study are increased to the extent that they are economically
relevant with respect to the facts and circumstances of the
On this matter, the new requirements are aligned with the
documentation requested in audits, which is reflected in this
Additional requirements related to article 762-F of the tax
code on corporate group information and documentation have been
incorporated for the purpose of promoting analysis sufficiency,
insofar as they are economically relevant.
It is important to mention that these transfer pricing
studies for the 2016 period must comply with the new
requirements set forth in this decree.
Another issue of great significance is the transfer pricing
audits for those taxpayers operating from the Colon free trade
zone. On July 29 2015, the Ministry of Economy and Finances'
tax director stated on his Twitter account: "Transfer pricing
rules apply, even if they are only relevant for the calculation
of CAIR – Alternative Minimum Tax Calculation. There
is already a precedent."
With regards to the aforementioned, the tax authority has
provided a new definition to the taxpayers subject to this
regime, based on the argument that the complementary tax, which
represents an advance of the dividend tax, is combined with the
income tax, in order to determine taxable income for both the
taxpayer and the shareholder.
For the tax authority, there is no need to amend the tax
code because the standard is very clear. Consequently, TP rules
will still apply for taxpayers who exclusively execute foreign
operations within a special tax regime and only generate income
exempt from income tax.
As expected, Peruvian TP Rules were modified starting 2017
in order to align them with the OECD's standards and
recommendations. Part of the OECD's BEPS project
recommendations were also introduced. The changes are related
to the so-called 'sixth method', intragroup services, the
inclusion of 'other methods' and the implementation of new
formal obligations related to OECD's BEPS Action 13.
One of the main changes is the introduction of the section
related to intragroup services. The deduction of costs or
expenses for services has been conditioned to the compliance of
the benefit test and to the disclosure of certain documentation
and information to Peruvian tax authorities. According to the
new legislation, the benefit test would be fulfilled when the
service rendered provides economical or commercial value to the
service recipient, improving or maintaining its commercial
position. The deduction of costs or expenses for the service
received will be determined on the basis of the addition of the
costs and expenses incurred by the service provider as well as
its profit margin.
The intragroup services rules also include the
characterisation of the 'low-value added' services, for which
the margin may not exceed 5% of the costs and expenses incurred
by the provider. According to the law, 'low value added'
services would be those that comply with the following
conditions: (i) have support nature; (ii) are not the core
business of the group; (iii) do not need the use nor the
creation of unique and valuable intangibles assets; and (iv) do
not imply the assumption of significant risks by the service
As for the documentation that tax authorities may require,
the new rules state that it must demonstrate the effective
provision of the service, the nature of the service, the need
for the service, the costs and expenses incurred by the
provider and the reasonable criteria for its allocation.
The 'sixth method' was also modified in order to align it
with the commodities' transactions section of the BEPS plan.
However, there are important differences between the OECD
recommendations and our legislation, which establishes that the
comparable uncontrolled price method is the most appropriate
one in order to evaluate the import and export of commodities.
The main difference lies in the 'pricing date' for the
commodity. While Peruvian TP rules state that the market value
in such transactions would be based on the international
quotation price of such commodity on the shipment date, OECD
recommendations propose a more flexible approach in relation to
the 'pricing date' criteria. However, in order for this method
to be applicable, complimentary rules should be published in
order to define the type of goods included, the market from
which the quote is obtained, the quotation to be considered of
that market and adjustments that would be accepted to reflect
the characteristics of the good and the type of operation.
The possibility of using other methods was also introduced
when the application of the methods already allowed is not
appropriate due to the nature and characteristics of the
activities and transactions under analysis. It is expected that
the regulations necessary to apply the law specify those
transactions that may be subject to new methodologies and
confirm that such 'other methods' would be mainly related to
valuation techniques commonly used for the transfer of
Finally, new formal obligations were introduced, in line
with OECD's BEPS Action 13 (documentation requirements).
Taxpayers will be subject to the scope of application of such
obligations as follows:
- Local file affidavit. For taxpayers with
annual accrued income exceeding 2,300 tax units ($2.8
million), in respect to transactions that generate taxed
income and or deductible costs or expenses. This obligation
is the one that replaces the former obligations, which were
TP technical report and TP informative affidavit.
- Master file affidavit. For taxpayers that
are part of a group whose accrued income exceeds 20,000 tax
units ($24.7 million).
- CbC report affidavit. For taxpayers that
belong to a multinational group. The presentation of the
local report affidavit is effective from 2017 (referred to
intercompany transactions performed in 2016), while the
presentation of the master report affidavit and the CbC
affidavit will become effective from 2018. Although all of
these changes are already in force, we are still expecting
the complimentary regulations to be published, in order to
clarify doubts regarding the filing of the master file and
CbC report affidavits, and also regarding the content and
template of the local file as well as the deadlines for the
filing of such affidavits this year.
The Tax Transparency Act (Act 19.484) was approved in
January 2017. Regarding TP issues, most relevant aspects of the
law are the following. The tax authority is entitled to adapt
TP requirements to the standard of OECD's BEPS Action 13 (local
file, master file and CbC report).
The requirement of the CbC report will be in force for the
fiscal year starting after January 1 2017. Local companies of
multinational groups must file the report in Uruguay unless
such report is filed in a country with which Uruguay could
exchange the report. In such case, the Uruguayan entity will be
subject to notification requirements.
With reference to the master file, the tax authority has not
yet defined the scope of the requirement.
The tax authority is now allowed to issue multilateral
advance pricing agreements. Since the first adoption of TP
rules in Uruguay, unilateral APAs were permitted, however, not
many taxpayers have been interested in the procedure and just a
few ended up reaching an agreement with the tax authority.
In line with the above, the tax authority has reformulated
the TP form that is filed together with the TP report by those
entities subject to filing requirements. The new version
requires very detailed information, not only on the
transactions but also on the functional and economic
On July 10, the OECD released the 2017 edition of the
Transfer Pricing Guidelines for Multinational Enterprises and
Tax Administrations. The TP guidelines provide guidance on the
application of the arm's-length principle and serve as a
framework for the consideration of all transfer prices between
The last edition of the transfer pricing guidelines was
released in 2010. The guidelines were amended in 2016 to
reflect updates stemming from the 2015 BEPS project. The 2017
transfer pricing guidelines incorporate the BEPS framework.
The above-mentioned guidelines have not been formally
incorporated into the Venezuelan legislation, however,
considering that said legislation (Income Tax Law Article 113)
establishes that for everything not considered in said law, TP
guides for multinational companies and fiscal administrations
approved by the OECD will be applicable and become part of the
TP regime of Venezuelan legislation.
Florida 234, Floor 5th
Ciudad Autonoma de Buenos
Buenos Aires C1005AAF
Tel: +54 11 4320 4046
Silvana Blanco is a partner in the transfer pricing
service team of Deloitte Argentina. She has been
working at the transfer pricing department since its
inception. From the beginning of the application of
transfer pricing standards in Argentina, Silvana has
engaged actively with the administration officers.
She has more than 19 years of experience in the
application of tax, economic and financial criteria in
transfer pricing, valuation analysis of intangibles,
planning, business model optimisation, structuring and
economic consulting. In the context of her expertise,
Silvana has experience in fields such as the
coordination of multi-country transfer pricing
assignments for multinational groups, the optimisation
of tax burden, and information requests posed by tax
authorities in main industries such as the automotive
industry, the oil seeds industry and the pharmaceutical
She has actively participated as a speaker in
seminars and conferences at Bolsa de Cereales de Buenos
Aires, Consejo Profesional de Ciencias
Económicas de la Capital Federal, Bolsa de
Comercio de Rosario, Asociación Argentina de
Estudios Fiscales etc.
She has written many articles in newspapers and
local tax-focused publications such as Ámbito
Financiero, Colección Errepar, Buenos Aires
Herald, World Trade Executive etc. She is the cowriter
of Manual de Precios de Transferencia en Argentina (La
Silvana Blanco graduated as a certified public
accountant at Salvador University and holds a Master
degree in Strategic Business Administration and
Marketing from Universidad de Ciencias Empresariales y
She is a member of the International Fiscal
Association and part of the Transfer Pricing
Partner, international tax and transfer
Tel: +54 11 4321-3002
Fax: +54 11 4320 4066
Mobile: +54 9 11 51507222
Horacio Dinice is a tax partner at Deloitte
Argentina. He is mainly engaged in international tax
consulting and transfer pricing matters. His experience
covers a wide range of industries, but has been centred
on the pharmaceutical sector for many years.
He is in charge of the transfer pricing practice in
Buenos Aires and LATCO and is one of the partners
responsible for the international tax area.
His experience encompasses advising multinational
corporations on tax implications of cross-border
acquisitions/transactions and the establishment of
foreign operations in countries of the Latin American
region (Argentina, Bolivia, Paraguay &
- Lead partner on over 100
documentation studies per year
- Advisory for the international or
regional reorganisation of various clients
- Specialisation in cross-border
structuring for Argentinean and Latin American
- Participation in various mergers
and acquisitions in Argentina
- Development of linked regional
cross-border tax planning and transfer pricing
- Participation in various regional
and global transfer pricing projects
Awards, Recognitions, Achievements, and
- Professor of tax at the University
of Buenos Aires (1986-1992) & CEMA
- Frequent speaker at conferences
focusing on tax and transfer pricing issues
- Member of the AAEF (IFA member)
and participant of the Transfer Pricing
- Author of articles in
international tax publications
- He participated in technical
meetings of improvement and professional development
in other countries
- He dictated advanced training
courses organised by the company for professional
Professional Qualifications and Affiliations
Certified public accountant graduated in School in
Economic Sciences (University of Buenos Aires,
Carrera 7 74-09,
Tel: + 57 (1) 4262303
Bruno Urrieta is a partner in the Bogotá
office and responsible for the Colombian transfer
pricing practice. For more than 15 years he has
assisted multinational and national groups with
operations in different industries – mining,
manufacturing, media and entertainment, automotive,
real estate, hospitality, telecommunications, and
retail, among others – in the design,
implementation, and/or defense of their TP
Before joining Deloitte Colombia, Bruno was part of
the TP practice at the Mexico City office, where he
participated in different projects for some of the
largest Mexican multinational and national groups, and
subsidiaries of important US and Canadian companies
that included the application of economic and financial
criteria in transfer pricing, the design of
intercompany policies and methodologies, valuation of
intangible property, business model optimisation, tax
controversy situations, negotiation of advance pricing
agreements, and documentation projects in order to
comply with the local regulations. Additionally, Bruno
has broad experience coordinating regional TP
documentation and planning projects for multinational
groups that have operations in Latin and North America.
Finally, he has been the preferred TP adviser to one of
the largest Mexican conglomerates with operations in
the mining, construction, infrastructure, oil and gas,
real estate, and entertainment industries in Mexico,
South America, Spain, and the US.
Bruno is a member of Deloitte's technology, media
and entertainment and telecommunications tax practice,
and has worked on compliance and planning projects with
some of the major players in the Mexican and Latin
American advertising, media, and entertainment
Bruno holds a Master's degree in strategic business
consulting from the Universidad Panamericana and a BA
in economics from the Universidad Nacional
Autónoma de México.
Tax and transfer pricing partner
Tulcán 803 y 9 de Octubre, Ed. El
Contemporáneo, Piso 12
Tel: +593 (4) 3700-100 Ext.: 1111
Joseph Soto is an international tax partner in the
Guayaquil office of Deloitte Ecuador. He has more than
22 years of experience in tax consulting and transfer
pricing for local and multinational corporations. He is
a tax and transfer pricing partner and the TP leader
for the Ecuador office.
Joseph has a portfolio of clients that includes
multinational and local business groups to whom he
provides advisory services, tax planning, due
diligences services, and tax advice on M&A,
including manufacturers, distributors, commercial,
telecommunications, services, shipping, airlines, and
He is a graduate of the University of Guayaquil and
holds an executive master's degree in business
administration. He is also a member of the Ecuadorian
Institute of Tax Law and the Deloitte tax practice
Joseph has taught taxation subjects in Ecuadorian
universities and he has participated as a speaker in
business development seminars and in tax matters and
transfer pricing programmes.
Joseph regularly contributes articles to various
publications specialising in tax and transfer pricing
Partner, tax and legal
Deloitte El Salvador
Tel: +503 2524 4100
Mobile: +503 7854 6968
Fax: +503 2524 4126
Federico has a BBA from Franklin University. He is
the leader of the tax and legal practice in Deloitte's
El Salvador office with more than 20 years of
experience providing tax advisory services. His main
experience includes corporate tax advisory,
international tax consulting in the Central American
countries, transfer pricing, tax defense and due
As part of his professional development he has
participated in different international courses.
He has also been a speaker in several local and
international seminars and conferences about taxes and
transfer pricing topics.
Federico is a member of the tax committee of the
American Chamber of Commerce in El Salvador.
His experience includes topics such as tax and
business advisory, including the following service
lines and solutions: tax consulting, tax compliance,
tax planning, international taxes, M&A, joint
ventures, strategic tax-related planning, tax reviews,
tax audits, tax due diligence and tax controversy
services and transfer pricing. He has also led some
relevant due diligence processes in the region. He
speaks Spanish and English.
Partner | Tax & Legal | Transfer Pricing
5 Avenida 5-55 zona 14, Europlaza Torre IV, Nivel 8.
Tel/Direct +502 2384 6500
Byron Martinez is the CEO for Deloitte Guatemala and
He is also the leader of Deloitte Guatemala's
transfer pricing practice and the tax risk leader for
Deloitte LATCO, a cluster organisation comprising 15
Latin American countries.
With Guatemala's adoption of transfer pricing
regulations in 2012, Byron took charge of developing
the Deloitte Guatemala transfer pricing practice.
During his 28-year long career as a tax consultant,
he has developed extensive experience in providing
multinational clients the following services: transfer
pricing and tax consulting, tax compliance, tax and
legal assistance in M&A, restructurings, and spin
offs, tax controversies, strategic tax planning,
outsourcing of the tax function and statutory
accounting processes, project finance-related tax
planning, and local employee and expatriate planning
Byron has also provided consulting services related
to utilising government incentives such as drawbacks,
exports, free zones and bonded warehouses. His industry
experience covers banking and finance, consumer
business (retail, food and beverages, pharmaceuticals)
oil and gas, utilities, telecom, services,
manufacturing, transportation, real estate, exporting,
and free trade zones.
Byron has published numerous articles on transfer
pricing and speaks frequently on transfer pricing
issues. He is a professor in taxation at his alma mater
the Universidad Rafael Landivar.
Byron is a public accountant and auditor with a
Master's degree in finance, incorporated in the
Guatemala Public Accountants and Auditors Bar.
Director, International Tax and Transfer
Tel: +507 303 4100
Role on Engagement
Rosemari is the director in charge of transfer
pricing issues in Panamá.
Rosemari has over 20 years of experience in the area
of national and international taxation, particularly in
tax returns, tax reviews, tax planning, due diligence,
successions, organisational structures, indirect tax,
international tax, transfer pricing and accounting.
Her professional career began in Deloitte Venezuela
– Lara Marambio & Asociados. She started
as bookkeeper and later became director of tax.
Since 2012, she has developed the practice of
international taxation and transfer pricing at the
Deloitte office in Panama.
- Certified public accountant.
- Master's degree in business tax
- Member of International Fiscal
- Certificate ITC Leiden Latin
Gloria Guevara is the partner responsible for the
transfer pricing practice in Deloitte Peru. Gloria has
more than 15 years of experience with Deloitte, during
which she has advised multinational companies and key
local groups operating in diverse industries such as
mining, oil and gas, energy, manufacturing,
pharmaceutical, consumer business and telecom, media
and technology, among others.
Gloria has extensive experience advising her clients
on strategic planning design and transfer pricing
policies. She has actively participated in high level
complexity transfer pricing issues (valuation of
intangibles, valuation of mining properties, and
residual profit split application), as well as diverse
audit defenses regarding this field. She has also
advised one of our main clients in the telecom industry
on the negotiation of an advance pricing agreement with
the national tax administration.
Her experience includes advising strategic clients
from mining, telecom and media industries on audit
defense, transfer pricing planning for shared service
centers and intangible valuation for high level
complexity operations related to business restructuring
for clients in the consumer business, mining, and TMT
Gloria is also the TMT industry leader at Deloitte
Peru. In this role, she is responsible for coordinating
and promoting all the services that the firm can offer
to the TMT (Technology, Media and Telecommunications)
current and potential clients throughout the different
business lines. Her responsibilities also extend to the
coordination with the TMT regional and global leaders
in order to better serve our global TMT clients. Gloria
is a frequent speaker on transfer pricing.
- Adolfo Ibáñez School
of Management (Lima-Miami): Executive MBA, class of
- Pontificia Universidad
Católica del Perú: Degree in economics
in July 2006. Graduated holding the highest score of
the graduation class.
- Universidad de Lima, Perú:
Post graduation degree in businesses' economic
management (December 2004).
- Pontificia Universidad
Católica del Perú: Social Sciences
Degree with major in economics (March 1998 –
December 2002). Graduated third in the graduation
Tel: +598 2916 0756
Alejandra is a senior manager in the transfer pricing
practice of Deloitte Uruguay. She has been working in
different areas of Deloitte's tax department since
1997. She also worked for the transfer pricing practice
of Deloitte Argentina for a few months. During this
period she accumulated significant experience in
various advisory services to foreign companies: tax
compliance, local and international tax planning and
transfer pricing. Her experience in transfer pricing
projects includes planning projects, documentation
projects and also defense in tax audits. She has
received training locally in the tax area, while she
participated in several TP courses in Uruguay and
- Certified Public Accountant,
Universidad de la República, Uruguay
- Degree in Taxation, Universidad
Católica del Uruguay
Partner, transfer pricing
Tel: +58 (212) 206 8778; +58 (212)
Public accountant. Master in tax management. Iliana
has more than 19 years of experience providing tax
technical advisory in transfer pricing matters. She
contributes to the development of the Deloitte's Andean
region transfer pricing practices.
Wide experience in the preparation and review of TP
documentation in different industry sectors, e.g.
automotive, pharmaceutical, basic materials, mining,
chemicals, and services, among others.
She has been actively involved in the development of
projects for documenting and designing TP policies,
strategies and structures for multinational groups.
Experience in the preparation of the defense of TP
audits in Venezuela.
Iliana is a frequent speaker at different TP-related
conferences in the Andean region.