Simulation of legal acts by operations between related parties A latent risk for taxpayers is the classification of their operations with related parties as simulated operations, which may have implications even of a criminal nature. In this study, we review the assumptions in which taxpayers would be in these circumstances and provide recommendations about the
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
