After years of debate, delay and controversy, the US has signed its double tax treaty with Venezuela. It is the first between the US and a Latin American country outside of NAFTA members. The treaty breaks new ground as Venezuela, like many other Latin American jurisdictions, has a territorial tax system. The hope is that the precedent set will be followed throughout the region.
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Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default