According to the Annual Tax and Customs Control Plan for 2022, the Tax Agency has intensified control over related transactions on intangibles such as startups.
Under the OECD, there will be a high level of control over those startups whose line of business is the exploitation of intangible assets or the performance of operations on such assets at the group level.
In this regard, startups that meet the aforementioned characteristics should review their transfer pricing policy and documentation obligations compliance.
Thus, there is no litigation with the Tax Agency, which has prioritized related international operations due to the inherent tax risk in this type of operations this year.
Source: El Referente 08/02/22
