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  • Since the arm's-length principle was introduced in Peru in 2001, there have been multiple updates and extensions to the rules on transfer pricing. Claudia González-Béndiksen and Paola Gutiérrez list the important points taxpayers must be aware of, such as maintaining stringent documentation as well as filing an annual sworn informative return.
  • With transfer pricing rules only introduced in 2005, Ecuador is still feeling its way through the implications. Diego González-Béndiksen and Diego Almeida talk through what taxpayers can and cannot do under the fledgling laws.
  • Transfer pricing legislation is relatively new in Colombia and with taxpayers, advisers and officials still finding their way, questions are still being asked. Diego González-Béndiksen and Rhina Toro Infante warn severe penalities wait for those who do not manage to comply.
  • In Chile, the rules technically follow the OECD guidelines, but Miguel Zamora and Ana Paula Güitrón say it is not clear whether this is true. Advisers still struggle to know which transfer pricing methods are allowed.
  • Augusto Martín Camarero and Armando Cabrera describe the way Argentine transfer pricing rules still fall behind more developed tax codes. The lack of advance pricing agreements and quasi acceptance of secret comparables cause problems.
  • Over the last decade, Latin America has shown economic growth, commercial development and financial stability. Additionally, countries throughout the region have modified their regulations, implementing internationally accepted rules. Emerging economies in this region have been attracting foreign direct investment as never before, and Latin American corporations are nowadays renowned worldwide for their presence in different markets and for carrying out intercompany transactions that increase as globalisation does.
  • Simone Dias Musa, Clarissa Machado and Camilla Lagrasta explain how not following the OECD guidelines makes the Brazilian rules difficult to follow. With fixed margins regardless of industry and new thin capitalization rules, taxpayers need to be aware of the complex legislation.
  • The Caribbean island state of Antigua and Barbuda has engaged US law firm Rubenstein & Rubenstein to rewrite a selection of the jurisdiction's tax laws.
  • The IRS has issued guidance to taxpayers on how the tax authorities will interpret certain sections of the Foreign Account Tax Compliance Act (FATCA) that were enacted in the Hiring Incentives to Restore Employment (HIRE) Act in March 2010.
  • Kazakhstan will double its export duty on crude oil to $40 per tonne in 2011.
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