Data base on transfer pricing rules and practices in Latin American and Caribbean countries

 Thanks to the contributions of 24 tax administrations from Latin American and Caribbean countries, the CIAT Executive Secretariat makes available to the international tax community, this Data base on transfer pricing rules and practices, updated through April 2018.

In case users may have observations or questions regarding the information in this Data Base, please contact Mr. Isaác G. Arias E., International Cooperation and Taxation Director (garias@ciat.org), Mrs. Omaraly Blanco Viloria, International Taxation Coordinator (oblanco@ciat.org) and Ms. Anarella Calderoni (acalderoni@ciat.org).

Section I – Updated to April 2018 in terms of regulatory aspects. The updating of statistical and management information varies according to the country.

General aspects

Related parties

Formal obligations

Sanctioning System

Functional Analysis

Methods

Financial Indicators

Adjustment

Experience in Transfer Pricing Control

Judicial Aspects

Human Resources

Data Sources

Advance Pricing Agreements (APA’s)

Simplified measures

Double Taxation Agreements (DTA’s)

Tax Info Exchange

Anti-abuse rules

Aspects related to the BEPS Project of the OCDE

Tax Haven

Section II – Updated to September 2018 in terms of regulatory aspects. The updating of statistical and management information varies according to the country.

Advance Pricing Agreements

Correlative, secondary and self-adjusting adjustments

Formal evaluations

Sources of information for the control of transfer prices

Exchange of information for tax purposes

Interest rates

Simplified measures for transfer pricing control

Tested party

Comparables

Controls

Verdicts on transfer prices

Formal Obligations

Human Resources

Economic sectors 

Section III -Sixth Method. The updating of statistical and management information varies according to the country.

Updates dates of data classified by country

Rules that regulate the measure

Legal nature of the Institute

Need to achieve the Arm’s Length Principle

Characteristics of the measure

Characteristics of the reference markets for the application of the measure

Economic Sectors in which the measure is applied

Adjustments applicable for the application of the measure

Main challenges detected when applying the “sixth method”

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