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    Transfer Pricing

    Technical Study of Transfer Pricing

    We provide advice for compliance of the Transfer Pricing Legislation applicable to each country, responsible for the analysis and execution of all phases involved in the completion of the Technical Study of Transfer Pricing (TSTP), providing a complementary support service after the delivery of said report when the Tax Authority requests it or carries out an inspection process.

    In our team we have the experience and knowledge to guide you in the process of surveying, presenting and supporting information related to transfer prices, with the aim of complying with the provisions of the Local Tax Administration. Also, we have experience in the execution of projects at an international level, as we are members of a global network, we share strategic experiences regarding transfer pricing at a broader level.

    The process for conducting the TSTP includes knowledge of the core business of the analyzed company, macroeconomic and sectoral analysis, analysis of transactions carried out with connected or related parties, and finally the development of transfer pricing methodologies applicable to each country.

    Annual Informative Affidavit

    We have extensive experience in making the Annual Transfer Price Affidavit applicable to companies located in South America (Argentina, Bolivia, Chile, Colombia, Ecuador and Peru), Central America (Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua, Panama and Dominican Republic), Mexico and Spain; within the terms and dispositions established by each jurisdiction.

    We are licensees of the software “TP Catalyst Bureau van Dijk” (updated with Osiris), which is a database that includes financial and statistical information of more than 80 thousand companies from 140 countries: financial statements, market reports, ratings, information of directors and managers staff, news, among other relevant data. The information included is provided by multinational firms such as Fitch Ratings, Reuters, World’ Vest Base, among others.

    Also, we have access to the international database “Veritrade Business”, which has financial information regarding exports and imports of companies from the American continent.

    Additionally, we have the “Royalty Stat” software license, which provides processed data and specific tools to determine royalty rates and benefit indicators for each industry.

    Strategic Planning of Transfer Prices

    We are specialists in developing Strategic Planning of Transfer Pricing Studies, which ensures your company to be anticipated to an audit or any other inconvenience caused by conducting transactions with related parties, as well as taking advantage of the opportunities for tax savings that are inherent in your development plans.

    Currently, it is recommended that when it is projected to execute operations with related parties and/or residents in tax heaven, it should be planned if these operations will comply with the principle of free competition. The advantages are to obtain a better tax efficiency, avoid the double imposition and prevent any future contingency before an eventual audit from the Tax Authority.

    Our staff is composed by a group of multidisciplinary professionals, dedicated to the development of financial and economic analysis necessary for the performance of each project. Our recommendations are not only limited to the merely tax aspect, but they also cover aspects at a strategic level.

    Support in Audits

    We provide support to our clients in their operations carried out with related parties and/or residents in tax heaven before an eventual audit by the Tax Authority. Currently, it has taken an active posture regarding to the audits focused on the transfer pricing.

    The introduction of the Transfer Prices Affidavit provided the Tax Administration with substantial access to information on transactions carried out by taxpayers with related parties, using it as a tool that allows the selection of companies and transactions that could be inspected.

    Also, the Tax Authority may disregard or not share the criteria to determine the prices or profit margins for transactions carried out with related parties or tax havens. Reason for which the support that we offer in front of this eventuality, with experts in the subject of different professions (lawyers, economists, accountants, administrators, etc.), assures a proper defense of the position of your company.