3.14. Improper contractual allocation of risk
| AUTHORS | |
|---|---|
| Wanda Montero Cuello, Iratxe Sáenz de Villaverde Musitu and Ana Rodríguez Calderón | |
| lectronic document | |
| Spanish and English | |
| CIAT | July 2023 |
Contents note:
The CIAT Executive Secretariat invites you to download and read chapter 3.14. “Improper contractual allocation of risk” of the Manual for the Control of International Tax Planning. This section was prepared by Ana Rodríguez Calderón, Wanda Montero Cuello, and Iratxe Sáenz de Villaverde Musitu, within the framework of the cooperation that CIAT maintains with the OECD.
The objective of the chapter is to analyze the effects of allocating economically relevant risks in an operation between related parties, when determining the transfer price. Likewise, it deals with the mechanisms or procedures that a tax administration should consider adopting to identify and treat risks caused by a contractual assignment that is not consistent with reality.