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Latin America Transfer Pricing

  • Introduction

  • Argentina: Transfer pricing rules in need of change

    Augusto Martín Camarero and Armando Cabrera describe the way Argentine transfer pricing rules still fall behind more developed tax codes. The lack of advance pricing agreements and quasi acceptance of secret comparables cause problems.

  • Brazil: Caution advised to avoid disaster

    Simone Dias Musa, Clarissa Machado and Camilla Lagrasta explain how not following the OECD guidelines makes the Brazilian rules difficult to follow. With fixed margins regardless of industry and new thin capitalization rules, taxpayers need to be aware of the complex legislation.

  • Chile: Unclear if OECD principles apply to local rules

    In Chile, the rules technically follow the OECD guidelines, but Miguel Zamora and Ana Paula Güitrón say it is not clear whether this is true. Advisers still struggle to know which transfer pricing methods are allowed.

  • Colombia: Getting documentation right is crucial for taxpayers

    Transfer pricing legislation is relatively new in Colombia and with taxpayers, advisers and officials still finding their way, questions are still being asked. Diego González-Béndiksen and Rhina Toro Infante warn severe penalities wait for those who do not manage to comply.

  • Ecuador: Taxpayers racing to catch up as new rules settle in

    With transfer pricing rules only introduced in 2005, Ecuador is still feeling its way through the implications. Diego González-Béndiksen and Diego Almeida talk through what taxpayers can and cannot do under the fledgling laws.

  • Mexico: Moving forward along a different path

    In Mexico, the transfer pricing rules have been in force since 1997, a relatively long time in Latin America. Moisés Curiel, Carlos Linares and Emilio Angeles talk taxpayers through staying on the right side of the notoriously strict

  • Peru: Transfer pricing rules are developing rapidly

    Since the arm's-length principle was introduced in Peru in 2001, there have been multiple updates and extensions to the rules on transfer pricing. Claudia González-Béndiksen and Paola Gutiérrez list the important points taxpayers must be aware of, such as maintaining stringent documentation as well as filing an annual sworn informative return.

  • Uruguay: Newcomers to transfer pricing are still learning

    With enactments of important rules only taking place in 2009, transfer pricing regulations are still very new in Uruguay. Jonás Bergstein and Domingo Pereira explain how the new rules are changing business practices in Uruguay and demonstrate how closely the authorities are trying to follow the OECD guidelines.

  • Venezuela: Taxpayers are at risk of severe penalties

    Ronald Evans and Gustavo Sánchez discuss Venezuela's complex rules and explain that taxpayers must strive to comply with the legislation or face heavy penalties.


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