Review and Comparison of Transfer Pricing Regulations in Latin America, the United States and the OECD Guidelines

Deloitte; Banco Interamericano de Desenvolvimento (BID); Banque Interaméricaine de Développement (BID); Inter-American Development Bank (IDB); Banco Interamericano de Desarrollo (BID)

dc.creator	Deloitte
dc.creator	Banco Interamericano de Desenvolvimento (BID)
dc.creator	Banque Interaméricaine de Développement (BID)
dc.creator	Inter-American Development Bank (IDB)
dc.creator	Banco Interamericano de Desarrollo (BID)
dc.date	2010-11-10T22:34:32Z
dc.date	2010-11-10T22:34:32Z
dc.date	2001-01-31
dc.date	2013-12-29T09:10:01Z
dc.date.accessioned	2014-09-08T21:22:34Z
dc.date.available	2014-09-08T21:22:34Z
dc.date.issued	2014-09-08
dc.identifier	http://www.iadb.org/en/publications/publication-detail,7101.html?id=4594
dc.identifier.uri	https://saber.ucab.edu.ve/xmlui/handle/123456789/15433
dc.description	This report, prepared by Deloitte Touche Tohmatsu transfer pricing specialists with the funding of the IDB, compares the transfer pricing regulations in the OECD guidelines, which constitute the international standard that OECD member countries have agreed should be used in analyzing transfer pricing issues between multinational enterprises and tax administrations, and the situation in Argentina, Brazil, Mexico, the United States, and Venezuela. It concludes that transfer pricing policies are not exclusively about taxation. Transfer pricing regulations should enable tax administrations to obtain a fair tax base at the same time they minimize the risks of double taxation for multinational enterprises. The OECD Guidelines provide the guidance on transfer pricing issues for both taxpayers and tax authorities by establishing a comparison with what would have happened between independent enterprises. However, there is no universal solution to transfer pricing issues in the OECD Guidelines. Also that the preface to the reform introducing the transfer pricing rules states that the tax administration, for purposes of computing the statutory margins for the import and export RP and cost plus methods, will take into consideration economic analysis by industry sector, branch of activity and based on the current economic situation. Adjustment will be allowed when the economic circumstances necessitate adjustment. This flexibility is different from the Brazilian rules, which provide fixed margins for all economic activities unless the taxpayer establishes a different margin with data from official publications or research carried out by a qualified firm. This report, prepared by Deloitte Touche Tohmatsu transfer pricing specialists with the funding of the IDB, compares the transfer pricing regulations in the OECD guidelines, which constitute the international standard that OECD member countries have agreed should be used in analyzing transfer pricing issues between multinational enterprises and tax administrations, and the situation in Argentina, Brazil, Mexico, the United States, and Venezuela. It concludes that transfer pricing policies are not exclusively about taxation. Transfer pricing regulations should enable tax administrations to obtain a fair tax base at the same time they minimize the risks of double taxation for multinational enterprises. The OECD Guidelines provide the guidance on transfer pricing issues for both taxpayers and tax authorities by establishing a comparison with what would have happened between independent enterprises. However, there is no universal solution to transfer pricing issues in the OECD Guidelines. Also that the preface to the reform introducing the transfer pricing rules states that the tax administration, for purposes of computing the statutory margins for the import and export RP and cost plus methods, will take into consideration economic analysis by industry sector, branch of activity and based on the current economic situation. Adjustment will be allowed when the economic circumstances necessitate adjustment. This flexibility is different from the Brazilian rules, which provide fixed margins for all economic activities unless the taxpayer establishes a different margin with data from official publications or research carried out by a qualified firm.
dc.format	ACROBAT
dc.language	en
dc.subject	Política Fiscal
dc.subject	Fiscal Policy
dc.subject	Política fiscal
dc.subject	Transfer Pricing Regulations
dc.subject	Latin America
dc.subject	OECD Guidelines
dc.title	Review and Comparison of Transfer Pricing Regulations in Latin America, the United States and the OECD Guidelines
dc.type	Technical Notes
dc.coverage	Argentina
dc.coverage	Argentine
dc.coverage	Argentina
dc.coverage	Argentina
dc.coverage	Brasil
dc.coverage	Brésil
dc.coverage	Brazil
dc.coverage	Brasil
dc.coverage	México
dc.coverage	Mexique
dc.coverage	Mexico
dc.coverage	México
dc.coverage	Estados Unidos
dc.coverage	États-Unis
dc.coverage	United States
dc.coverage	Estados Unidos
dc.coverage	Venezuela
dc.coverage	Venezuela
dc.coverage	Venezuela
dc.coverage	Venezuela