Archives: transfer pricing

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New transfer pricing requirements in Latin America under BEPS

This publication first appeared as a Latin America Alert on www.dlapiper.com. Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered … Continue Reading

Public Consultation RFB No. 011/2016 – BEPS’ Country-by-Country Report

By Alex Jorge, tax partner, and Marcelo Siqueira, senior tax associate, of Campos Mello Advogados in Brazil (in cooperation with DLA Piper) On November 7, 2016, the Brazilian Federal Revenue (“RFB”) released the draft of a proposed Normative Rule (Public Consultation RFB No. 11/2016 – click here) regulating the implementation of Country-by-Country Report (“CbC Report”) … Continue Reading

Latin American countries focus on new legislation around tax and transfer pricing – independence limitations in Ecuador

A recent report published by the United Nations’ Economic Commission for Latin America and the Caribbean (CEPAL) calculated that Latin American countries have lost more than US$98 billion in tax revenues simply  due to transfer pricing manipulation. Latin American countries are paying close attention to such reports, leading to changes in their local regulations or … Continue Reading
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