TP takes precedence across Latin America

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

TP takes precedence across Latin America

International Tax Review editor Joe Stanley-Smith introduces the 15th edition of the Latin America guide.

It will be no surprise to tax practitioners that four of the six articles in this year's edition of Latin America, concern transfer pricing (TP).

The OECD's BEPS actions have reverberated around the world and with implementation of several action points now underway, the ground under companies' feet is shifting. Without even mentioning country-by-country reporting, the BEPS project has thrown up issues enough issues to keep TP professionals very busy indeed.

These issues manifest themselves in different ways in different countries, with governments and tax authorities in different jurisdictions often taking wildly disparate approaches. This patchwork of implementation is a common theme around the world, not just in Latin America. Nonetheless, careful analysis of the LatAm landscape, which is a common theme of our articles, will put taxpayers in a stronger position moving forward.

Beyond BEPS, we see a South American perspective on one of the world's hottest tax-related talking points: the taxation of the digital economy. Chile, an OECD member, is one of a growing number of countries looking to take action to extract more revenue from large technology companies, which many people around the world feel are not paying their 'fair share'.

A trend more specific to Latin America is currency devaluation and volatility, from which most of the region's major economies have suffered during the past 12 months. Compared with last year, a dollar buys you one extra Brazilian real, an extra Mexican peso (in June it was as much as three extra pesos), an extra 21 Argentine pesos, an extra 128 Colombian pesos and an extra 62 Chilean pesos. The currency is performing better in the region's sixth-largest economy, Peru, but disastrously in the seventh-largest, Venezuela, where the bolivar is experiencing hyperinflation.

It's pertinent, therefore, that one of our articles explores the best methods for dealing with currency volatility, and the political instability which often leads to it.

I hope you enjoy the 15th edition of the Latin America guide.

Joe Stanley-Smith

Editor

International Tax Review

more across site & bottom lb ros

More from across our site

Ireland offers more than just its competitive corporate tax environment but a reduction in the US rate under a Trump administration could affect the country, experts tell ITR
The ‘big four’ firm was originally prohibited from tendering for government work until December 1 due to it tax leaks scandal, but ongoing investigations into the matter has seen the date extended
Approximately 74% of MAP cases in 2023 reached a full resolution, but new transfer pricing MAP cases fell by 16%
Brazil is looking to impose the OECD’s 15% global minimum tax on multinationals; in other news, PwC is set to pull out of Fiji
The Australian gold producer’s CEO was detained in Mali last week following discussions with the African nation’s tax authorities
The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world
Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners
The new guide also covers transfer pricing and states that all transactions between related parties must be at arm’s-length
Local experts suggest complexity within Italy’s tax system could explain why advisers lag behind their counterparts in other jurisdictions
The tie-up will add around three US-based tax partners to Herbert Smith Freehills’s international 17-partner practice
Gift this article