Márcio F. VerdiExecutive Secretary

Interamerican Center of Tax Administrations

Transfer Pricing DocumentationAccess to useful information

CONTEXT

100% of LAC countries have TP standards and have established an information regime

Few Caribbean countries have provisions in this regard.

THE GOOD THE BAD

The current regimes of information are of little use - statement, study, etc.

Little is known of relevant businesses in several countries

The DTCs/TIAES increase exponentiallyLittle is exchanged and there are no coordinated procedures in LAC

In some countries banking secrecy or inability to identify owners of assets remain in force

TAs believe that TP is a priority issue and gradually invest resources.

Information is asymmetrical and scarce due to various circumstances.

Most countries use commercial databases, Osiris being the most used.

Some countries have access to horizontal cooperation based on transparency standards.

Internal comparable are very hard to find and the external do not abound

WHAT INFORMATION IS NECESSARY FOR

THE TRANSFER PRICING CONTROL?

PROCESSES FOR WHAT? RISK MANAGEMENTCONTROL

WHAT INFORMATION EXISTS TO COMPLY WITH THE “ARM’S

LENGTH” PRINCIPLE?

WHAT HAPPENS IN LAC?

Information Regime of large companies in 5 LA countries

Information Regime of large companies in 5 LA countries

The road to CBCR

What is the level of knowledge in the region? What concerns exist?

Level of knowledge and some data from the region according to CIAT/TJN

What some LA countries

do?

The agreement was signed

by 3 countries

Only 50% reported

having an extensive

knowledge

87% needs are satisfied

by CBCR

75% require adjusting standards

Access:20% TAs

30% central DB

50% subsidiary

What are the remaining concerns?

Maturity

Number of countries

that implement

CBCR

Risk management

ThresholdAdjust the

current regimes

Modify rulesCooperative compliance

Dispute resolution

Access to information

Resistance of local

companies

Control/ Audit