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 it addresses topics such as what is an advance transfer pricing agreement and what is it used for, its variants, advantages and disadvantages, considerations for tax authorities, the procedure for negotiating an APA, the effect of the Covid19 pandemic on the negotiation of APAs, the status of the APA program in the Americas, and some recommendations for taxpayers.

CIAT’s Manual on the Control of International Tax Planning is prepared by the most distinguished tax experts in the continent and seeks to report on aspects of risk for taxpayers and weigh the control tools available to tax authorities. This section was dedicated to the memory of Robert Feinschreiber (October 2020), a distinguished and highly regarded professional in transfer pricing. Here is the link to the publication: https://www.ciat.org/ciats-manual-for-the-control-of-international-tax-planning-5-8-advance-pricing-agreements/?lang=en