LATAM Country Update – Tax and Transfer Pricing related developments

November 17, 20210

Most of the LATAM countries have been implemented BEPS Action 13 in their national legislation, following the trend of the rest of the world and trying to align their rules with the OECD global standards. In addition, they have been incorporating new measures in order to advance their tax models. This interactive webinar will cover the tax and transfer pricing updates in Argentina; Brazil; and the Andean Community (CAN), formed by Bolivia, Colombia, Ecuador and Peru.

Key Highlights of the Webinar:

1. Argentina

  • Modifications introduced by General Resolution 5010/2021 (“GR 5010/2021”), issued on June 2021 by the Argentine Tax Administration (i.e. AFIP). The new rules modify and complement the transfer pricing regulations released last year by General Resolution 4717/2020 (“GR 4717/2020”).
  • Description of the conditions required for the companies to be able to choose the new Simplified Regime for transfer pricing information reporting.
  • Recommendations and suggestions published by AFIP on May 2021 for the taxpayers to consider in their Transfer Pricing analysis for the fiscal years that were affected by the COVID-19 pandemic.

2. Brazil
Income tax Reform: The proposed bill (PL 2.337/2021) brings relevant changes related to Corporate Brazil’s Income Tax framework.

  • Adjustment of the personal income tax table
  • Fall in corporate income tax
  • Taxation of distributed Profits and Dividends
  • Change in taxation on investment
  • Fair market value adjustment of assets

Indirect Tax Reform: The proposed bill (PL 3.887/2020) simplifies and unifies the indirect tax framework:

  • End of PIS/COFINS
  • Creation of CBS
  • Transparency and simplification

OECD Transfer pricing developments:

  • Status of Arm’s length adoption
  • Pillar one and two

3. Andean Community

  • Status of the implementation of BEPS Action 13 in CAN countries and the impact of the Andean Community Tax Treaty.
  • Recent TP developments and TP Case Law.



  • 17th November 2021

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