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News & Analysis

Transfer Pricing Tax Risk

13 March 2026 by TPC Group - Chile

Tax risk is that faced by companies that may be paying or accounting for an incorrect amount of tax (including income tax and indirect taxes), or that the tax positions taken by a company are incompatible with the tax risk expectations that administrators have approved or consider prudent.

News & Analysis

Application of the DEMPE Methodology in Latin America and Central America: Cases, Challenges, and Obstacles. The Potential Effect on Royalty Calculation

17 February 2026 by TPC Group - Chile

The DEMPE analysis (Development, Enhancement, Maintenance, Protection, and Exploitation) is a transfer pricing approach used to evaluate intangible assets, seeking to identify which entity within a multinational group performs the substantive functions related to an intangible asset.
News & Analysis

Application of the Sixth Method in Latin American Countries

05 February 2024 by TPC Group

Latin American countries are mainly characterized as commodity exporters, playing a significant role in the supply of primary goods for the world's largest economies.
News & Analysis

Business Restructuring - Sales Models

05 February 2024 by TPC Group

Business Restructuring - Sales Models

News & Analysis

Cash pooling and it's transfer pricing implications

05 February 2024 by TPC Group

Liquidity in multinational companies is essential for their efficient performance and ability to meet their financial obligations.

News & Analysis

Coefficient of Variation and its Implication on Transfer Pricing

05 February 2024 by TPC Group

The Transfer Pricing analysis is performed by comparing related party transactions with independent (comparable) party transactions.

News & Analysis

Financial Guarantees and Transfer Pricing

05 February 2024 by TPC Group

A guarantee is the assumption of a commitment to pay or perform a contract by the guarantor to a secured entity if the obligor or debtor fails to comply with its contractual commitments.

News & Analysis

138 Countries Agree on a Historic Milestone to Implement a Global Tax Agreement

14 August 2023 by TPC Group - Peru

138 tax jurisdictions have agreed on a global reform regarding the international tax system.

News & Analysis

The IRS and its Fight to Reduce the Tax Evasion Risk from MNEs

11 August 2023 by TPC Group - Peru

At the seminar conducted on March 7, 2023, Jennifer Best, deputy commissioner of the U.S. Internal Revenue Service's (IRS) Large Business and International (LB&I) Division, focused on the government's ongoing efforts to reduce excessive Transfer Mispricing practices by multinational enterprises aiming to reduce their taxes by shifting profits to tax havens.
News & Analysis

Tax Changes for 2023 and Their Effects on Transfer Pricing Rules

28 June 2023 by TPC Group - Peru

The tax authorities' innovations to be implemented must be known, concerning Transfer Pricing in particular.

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