Partner
Ecuador
+593984866479
World TP - Highly Regarded
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Transfer pricing
Support in complying with obligations regarding transfer pricing regime, advice and support in APA processes, contentious processes, planning and establishment of transfer pricing policies, expert reports for legal proceedings on transfer pricing, interpretation of agreements to avoid double taxation.
I supported the establishment of 3 APAs in 2021, however one was with a Company that belonged to an economic Group in country X that was absorbed by an economic Group Y and significant restructuring costs were generated. The APA included accuracy adjustments that better reflected the economic reality of the Company, avoiding multiple taxation. In addition, in control of the application of Agreements to Avoid Double Taxation, we have recovered in 2021 USD 20 million from non-residents of Ecuador but residents of a contracting state.