Given the complexity in applying transfer pricing methods, developing countries have innovated the creation of measures that allows them to address, in a simpler way, the main risks identified in the economic sectors that tend to manipulate transfer prices and minimize their taxes. A representative example of this in Latin America is the so-called “Six Method “ which was implemented, mainly to control the trade of commodities, at the legislative level in 10 countries with different approaches and results across the region.
In order to provide the international tax community with accurate and detailed information on the normative design and the results obtained because of the application of this measure, we have developed a special module within the CIAT Transfer Pricing Base, named the “Six Method.“ This module contains information on the 10 countries (Argentina, Bolivia, Brazil, Costa Rica, the Dominican Republic, Ecuador, Guatemala, Paraguay, Peru, and Uruguay) that have implemented the “Sixth Method”.
The aforementioned information is available in CIATData, in Spanish and English. We invite you to consult the following link of the Transfer Pricing Database: Transfer Pricing Database
The Executive Secretariat of CIAT is grateful to the GIZ of Germany for the financial support that has allowed CIAT to design the transfer pricing database and to the officials of the tax administrations of Latin America, who have provided quality information so that this new module could be completed.