3.12. Payments for technical assistance, royalties, interests, dividends, and service fees


Fernando Becerra O’Phelan and Giovanni Cerrón López
lectronic document
Spanish and English
 CIAT July 2022

Contents note:

The CIAT Executive Secretariat is pleased to present a new chapter of the Manual for the Control of International Tax Planning, entitled “Payments for technical assistance, royalties, interest, dividends and services”, prepared by  Fernando Becerra O’Phelan and Giovanni Cerrón López, which analyze the main risks to be taken into account when verifying these types of transactions, making use of practical examples for a better understanding. These examples focus on selected cases classified as high-risk for tax purposes, such as back-to-back loans and business restructurings, amongst others.

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