TP takes precedence across Latin America

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

TP takes precedence across Latin America

International Tax Review editor Joe Stanley-Smith introduces the 15th edition of the Latin America guide.

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 busy indeed.

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 America guide.

Joe Stanley-Smith

Editor

International Tax Review

more across site & shared bottom lb ros

More from across our site

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year
Gift this article