3.14. Improper contractual allocation of risk


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.

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