It will be no surprise to tax practitioners that four of the
six articles in this year's edition of Latin America, concern
transfer pricing (TP).
The OECD's BEPS actions have reverberated around the world
and with implementation of several action points now underway,
the ground under companies' feet is shifting. Without even
mentioning country-by-country reporting, the BEPS project has
thrown up issues enough issues to keep TP professionals very
These issues manifest themselves in different ways in
different countries, with governments and tax authorities in
different jurisdictions often taking wildly disparate
approaches. This patchwork of implementation is a common theme
around the world, not just in Latin America. Nonetheless,
careful analysis of the LatAm landscape, which is a common
theme of our articles, will put taxpayers in a stronger
position moving forward.
Beyond BEPS, we see a South American perspective on one of
the world's hottest tax-related talking points: the taxation of
the digital economy. Chile, an OECD member, is one of a growing
number of countries looking to take action to extract more
revenue from large technology companies, which many people
around the world feel are not paying their 'fair share'.
A trend more specific to Latin America is currency
devaluation and volatility, from which most of the region's
major economies have suffered during the past 12 months.
Compared with last year, a dollar buys you one extra Brazilian
real, an extra Mexican peso (in June it was as much as three
extra pesos), an extra 21 Argentine pesos, an extra 128
Colombian pesos and an extra 62 Chilean pesos. The currency is
performing better in the region's sixth-largest economy, Peru,
but disastrously in the seventh-largest, Venezuela, where the
bolivar is experiencing hyperinflation.
It's pertinent, therefore, that one of our articles explores
the best methods for dealing with currency volatility, and the
political instability which often leads to it.
I hope you enjoy the 15th edition of the Latin
International Tax Review