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Andersen Global Transfer Pricing Insights

Andersen Global Transfer Pricing Insights

How to understand the new rules of the current international scene? In today's globalized world, the practice of Transfer Pricing continues to grow, develop and intensify. This panorama not only means new business opportunities, but also exposes the tax authorities to...

read more

Transfer Pricing

Transfer Pricing (TP) has become one of the key areas of international taxation.

Hence, most countries have very strict TP rules and regulations in place so that tax authorities may make sure that the arms’ length standard is met in the transactions conducted between related parties.

Almost all Latin American countries, except for Paraguay, apply the principles and guidelines developed by the OECD.

Argentine laws have adopted similar parameters, but have extended controls to transactions carried out with persons residing in zero or low tax jurisdictions or non-cooperating jurisdictions, even when they are not related parties. It also includes some special controls on routed exports and imports (triangulations) and a Special Registry for Commodities exports.

We provide a highly specialized service to advise on international planning, annual compliance requirements, assistance in dispute resolution and in the process for Advance Transfer Pricing agreements.

COMPLIANCE WITH CONTROL REGULATIONS:

  • We prepare or revise Transfer Pricing Studies prepared by clients to ensure compliance with applicable rules and regulations. Studies include the comparability process, to which we apply the necessary rigor in order to minimize potential controversies with the tax authority
  • Studies involve preparing the local file and the master file and the tax returns that should be filed
  • We provide assistance with the obligations that should be complied with in routed import and export transactions and in registering transactions with commodities
  • We prepare preliminary reports to assist in the design of transfer pricing policies for multinational groups
  • We provide assistance in preparing the each “Country Report” and in fulfilling the reporting obligations applicable to the subsidiaries of multinational groups

REGIONAL COORDINATION:

Our regional presence allows us to obtain a broad vision of international operations, transferring experiences between countries and achieving coherence in the application of the Transfer Pricing policies of our clients

  • In the case of regional advisory services, the comparability analysis includes the balance and solvency of comparables for all countries involved
  • Regional coordination allows us to get a wider view of international operations, sharing experiences across countries and achieving consistency in the transfer pricing policies of multinational companies

DISPUTE RESOLUTION:

We defend the taxpayer’s position against possible adjustments by the tax authority, accompanying him from the start of the inspection to its definition in court in all contentious stages

  • Representation in defense of adjustments before the Tax Administration, the Tax Court and Justice
  • Preparation of technical expert reports
  • Defenses of value before Customs
  • Action in Mutual Agreement Procedures within the framework of the Agreements to Avoid Double Taxation
  • We provide support to face tax examinations/audits and defend clients in litigation processes, including the design of strategies and the representation and advise before jurisdictional authorities

ADVANCE PRICING AGREEMENTS:

  • We provide assistance to clients who file and apply for Joint Assessments for International Transaction Prices (DCPOI)

BUSINESS VALUATION:

  • We apply financial valuation techniques to companies and advise on negotiations in M&A processes

Related news

Andersen Global Transfer Pricing Insights

Andersen Global Transfer Pricing Insights

How to understand the new rules of the current international scene? In today's globalized world, the practice of Transfer Pricing continues to grow, develop and intensify. This panorama not only means new business opportunities, but also exposes the tax authorities to...

read more

Andersen, is the Argentinian member firm of Andersen Global®,

an international association of member firms

comprised of tax and legal professionals worldwide.