3.1. Thin-capitalization and other international financing operations


Jairo A. Godoy G.

Pablo Porporatto.

lectronic document
Spanish and English
 CIAT June 2023

Contents note:

The CIAT Executive Secretariat invites you to download and read section 3.1. Thin-capitalization and other international financing operations of the Manual for the Control of International Tax Planning, written by Jairo A. Godoy G. and Pablo Porporatto.

Section 3.1. presents rules for addressing possible abuses that arise when taxpayers use financial products or instruments with specific characteristics that are only available in international financial markets which offer more variety, sophistication and competitive conditions than that available in their local markets. In this sense, tax administrations must be prepared to identify and avoid these potential abuses and generate a dissuasive risk perception in taxpayers by carrying out an adequate risk analysis applied to the international financial transactions.

Section 3.1. is No. 18 published within the framework of the Manual for the Control of International Tax Planning and is available in English and Spanish. The complete Manual has six chapters made up of 42 sections. New sections will be published soon.

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