E-books

A practical guide on the application of the OECD Transfer Pricing Guidelines, with a special focus on Chile and Latin America. It presents the fundamentals of the arm’s length principle, comparability factors, the documentation required by tax authorities, and the main challenges faced by multinational companies in the region, offering a clear vision for strengthening tax compliance and transparency.

A specialized resource that addresses the fundamentals of transfer pricing in the international context, with a practical focus on Latin America. The eBook develops the arm’s length principle, functional analysis, method selection, and the importance of documentation as the cornerstone of tax compliance. It also examines the main challenges faced by business groups in tax audits and tax risk management, providing a clear vision for the proper control of their intra-group operations.

A practical guide to one of the fundamental pillars of Transfer Pricing. This publication explores the comparability principle as an essential element for determining whether transactions between related parties are conducted under conditions equivalent to those that independent parties would have agreed upon in similar circumstances. It analyzes comparability factors, functional analysis, valuation methods, and the importance of the adjustments necessary to ensure the proper application of the arm’s length principle, thereby strengthening the technical basis of Transfer Pricing policies and the defense against tax audits.

A work aimed at understanding how the OECD Guidelines seek to ensure that the profits earned by multinational groups are allocated in accordance with the activities that actually generate value. It examines key concepts such as economic substance, functions performed, assets used, risks assumed, and the role of intangibles in value creation. It also addresses the importance of aligning financial results with the economic reality of operations to promote more transparent and sustainable taxation.

An essential reference for understanding the international methodologies used in determining the market value of transactions between related parties. It explains traditional methods based on comparable transactions and methods based on profits, analyzing their characteristics, advantages, limitations, and criteria for application. The publication provides practical tools for selecting the most appropriate method based on the nature of the transaction and the availability of comparable information.

A comprehensive overview of the evolution of the Transfer Pricing regime in Chile and its alignment with international standards promoted by the OECD. It reviews the main regulatory aspects contained in Article 41 E of the Income Tax Law, the tax authority’s audit powers, and the documentation obligations arising from Action 13 of the BEPS Plan, including the Local File, the Master File, and the Country by Country Report.

A publication that analyzes the development and application of Transfer Pricing rules in the region’s major economies, with a special focus on Peru, Mexico, and Colombia. It presents the legal foundations, compliance obligations, regulatory trends, and the incorporation of OECD recommendations, offering a comparative overview of the challenges and opportunities facing multinational companies in Latin America.

Tax administrations have significantly increased their monitoring of corporate profitability as a mechanism for controlling and evaluating compliance with the arm’s length principle. This publication analyzes the methodologies used by various tax authorities to identify deviations in financial results, the use of sector-specific indicators and benchmarking studies, as well as the implications these approaches have for companies’ tax risk management.

A guide focused on identifying, assessing, and managing tax risks associated with transactions between related parties. It explores concepts related to internal tax control, corporate governance, strategic tax planning, and sustainable tax compliance, highlighting the importance of adopting preventive measures to reduce contingencies and strengthen organizations’ legal certainty.

Tax sustainability has become a fundamental component of modern business management. This publication explores the relationship between tax transparency, collaborative compliance, and corporate responsibility, addressing initiatives such as tax sustainability certification and tax control frameworks. It also analyzes how these tools contribute to strengthening trust between taxpayers and tax authorities.

A detailed explanation of the main amendments introduced by Law No. 21,713 to the Chilean Transfer Pricing regime. The changes related to advance pricing agreements, the criteria applicable to low-tax jurisdictions, the elimination of certain penalties, and the updating of various aspects in line with the OECD Guidelines are examined, thereby strengthening legal certainty and regulatory modernization.

A publication focused on the audit processes applied by tax authorities regarding Transfer Pricing. It analyzes the objectives of tax audits, the high-risk areas identified by the authorities, and the importance of having robust and up-to-date technical documentation. Additionally, it presents international best practices for handling audits and minimizing tax disputes.

A specialized guide on advance transfer pricing agreements as a tool for preventing disputes and strengthening tax compliance. It explains their main characteristics, types—unilateral, bilateral, and multilateral—benefits for taxpayers and tax authorities, as well as their growing importance within the collaborative compliance models promoted by modern tax authorities.