A perspective on the evolution of transfer pricing regimes in Latin America Background Transfer pricing regimes make their formal appearance in Latin America in the 1990s, where, as a result of the liberalization process of the economies, signing of trade agreements and negotiation of treaties to avoid double taxation it became urgent to establish a
Do DEMPE rules reflect the reality of the market? In October 2015, the action plan to combat tax evasion and profit shifting (the BEPS plan) was published by the Organization for Economic Co-operation and Development (OECD). The BEPS plan contained 15 actions aimed at “realigning taxation with economic substance and value creation, while preventing double
CIAT’s Manual for the Control of International Tax Planning: Advance Pricing Agreements In the current month of June, the Inter-American Center of Tax Administrations (CIAT) published the section on transfer pricing agreements of its Manual for the Control of International Tax Planning. This section was in charge of our partner, Jesús Aldrin Rojas M., and
Mexico’s transfer pricing regime undergoes its most profound revision since its establishment Background Information One of the most important regimes that the country has at its disposal is the transfer pricing regime. This regime (in force in the country since 1997) seeks that the participants of an intercompany operation transact considering the terms that independent third parties
