The CIAT Executive Secretariat is pleased to announce that section 6.1 of the Manual for the Control of International Tax Planning, titled “6.1 Audit of Multinational Enterprises and Entities with International Operations”, is now available for officials  of tax administrations. This section was prepared by Marcia Grostein, a distinguished international taxation expert from Uruguay’s DGI.

This section provides a practical approach to strengthening the capacity of tax administrations to effectively audit multinational enterprises (MNEs) or international operations. In addition, the publication highlights the importance of training auditors and reinforcing the exchange of information among jurisdictions to ensure proper taxation in the place where value is created.

It details a comprehensive approach that includes:

• Review of informative returns and transfer pricing studies.
• Analysis of financial and operational flows through flowcharts.
• Identification of functions, assets, and risks assumed by local entities.
• Segmentation of results and interviews with key personnel.

The chapter offers detailed examples of real audits, including cases of restructurings, interposition of entities with low substance, thin capitalization, and interest payments that could conceal dividend distributions.

This is the last section released as part of the Manual for the Control of International Tax Planning, which is available in both spanish and english. The full manual consists of six sections and 42 chapters.

Note: Due to the nature of their contents, this section and section 5.2 of the Manual will only be available to officials from CIAT member tax administrations, upon request via the following email address: tributacion_internacional@ciat.org.

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