Transfer pricing: here’s what the rules in Latin America look like

Latin America has been implementing in its tax law provisions for combatting base erosion by any other type of company that has a presence in various countries in the region.

One of the tax authorities’ most important tools for preventing the avoidance or evasion of obligations by taxpayers are transfer pricing rules, taken directly from the Transfer Pricing Guidelines for Multinationals and Tax Administrations (TPG) drawn up by the Organization for Economic Cooperation and Development (OECD). These guidelines have been used as a basis for including transfer pricing rules or regimes in local laws. Except for specific provisions on filing dates or document requirements, the transfer pricing rules in Latin America mirror the OECD’s guidelines and are quite similar among the various Latin American countries.

Moreover, the region’s tax authorities, specifically those in Brazil, Chile, Colombia, Mexico and Peru, countries where Garrigues has a direct presence, have been introducing the recommendations that have come out of the OECD’s Base Erosion Profit Shifting (BEPS) project, aimed at combating base erosion and profit shifting worldwide.

Here you can find a country-by-country analysis.