TPA Global Webinars 2018

The impact of BEPS Action 13 for MNEs operating in LATAM

Countries in LATAM as Argentina, Brazil, Chile, Colombia, Mexico, Peru and Uruguay have been implementing in their domestic legislations some or all of the three-tiered Transfer Pricing (TP) documentation (Country by Country report, Master File and Local file) recommended by the OECD on Action 13 of BEPS project.  Hence, multinational enterprises operating in the region are required to fill this new TP documentation in compliance with the OECD standards and the specific regulations of the particular country.

In this context, we would like to invite you to our webinars where our Alliance Partners of Argentina, Brazil, Chile, Colombia, Mexico, Peru and Uruguay,  will discuss about the implementation of the of the three-tiered documentation in these countries, the relevant characteristics of this documentation and as well the impact of these requirements for companies operating in the region.

In addition, we will discuss the regional integration of Transfer Pricing in Central America (Costa Rica, Guatemala, El Salvador, Honduras, Nicaragua and Panama).

The webinar will consider the following:

  1. General presentation of the Argentinian, Brazilian and Peruvian Transfer Pricing legislation incorporated in accordance with Action 13 of BEPS.
  2. Update of the actions that the mentioned countries have taken after such implementation i.e. regulations and guidance.
  3. Impact of these new TP documentation requirements for MNEs operating in LATAM.
  4. The main challenges faced by companies and tax authorities in the referred countries.
  5. The regional integration of Transfer Pricing in Central America (Costa Rica, Guatemala, El Salvador, Honduras, Nicaragua and Panama)


- Belisa Severini, Senior Associate, TPA Global, Argentina
- Sonia Catalina Muñoz Rodriquez, Junior Associate, TPA Global, The Netherlands
- Jorge De la Rosa, TPA Global Member, Mexico
- Luis Ugarelli, TPA Global Alliance Partner, Peru
- Hermano A. C. Notaroberto Barbosa, Brazil

Thursday, January 11, 2018

Argentina, Brazil, Peru and Central America

10:00 AM - 11:00 AM Mexico, USA and Canada
2:00 PM - 3:00 PM Brazil
4:00 PM - 5:00 PM London (GMT)
5:00 PM - 6:00 PM Amsterdam (CET)

Register (Spanish)

Mapping the Trends in MAP Resolution of Tax Treaty Disputes after BEPS

A presentation on the improvements BEPS has made to the resolution of international tax disputes through the Mutual Agreement Procedure (MAP) under tax treaties.

The traditional failures of the MAP procedure are all too well known. MAP is lengthy and does not hold any guarantee of a solution, if it can be accessed at all. However, there is now substantial repair provided under BEPS, which may be viewed as counter-balancing the anti-tax avoidance measures that BEPS holds and proposes. Disputes are expected to increase significantly due to such BEPS measures, affecting mostly the area of transfer pricing and connected P.E. and withholding tax issues. As result, the demand for MAP resolution will increase as well.

The improvements made relate mainly to MAP access for taxpayers, various MAP timelines, and the implementation of MAP results. In addition, BEPS has set a range of minimum standards for authorities’ proper MAP conduct, that are in the process of becoming widely adopted through the global membership of the BEPS Inclusive Framework, comprising already of over 100 countries. There are peer reviews being conducted to monitor countries’ observance of these minimum standards, the results of which are captured in public reports.

To guarantee a timely MAP resolution, BEPS further provides for mandatory binding arbitration, be it still only on an optional basis. There are at present 25 countries that have committed themselves to this MAP arbitration; most of these include OECD member countries, but also others such as Singapore. The recent 2017 Update of the OECD Model Income Tax Convention shows a fortunate trend of countries gradually abandoning prior principled reservations against MAP arbitration.

There are some remaining weaknesses, however, in particular the extent of taxpayer rights and participation under the MAP and MAP arbitration procedures that BEPS leaves to the discretion of authorities individually.

TPA Global has initiated a series of webinars covering the global impact of emerging BEPS developments on various international structures. In the 3rd webinar of this series, we will analyze if the improvements made under BEPS indeed result in a MAP procedure becoming more attractive for taxpayers to pursue, either instead of, or, as the case may be, next to domestic litigation.

Key Highlights of the webinar

  • Presentation of the following elements of BEPS dealing with MAP and MAP arbitration:
    • Action 14 – Making Dispute Resolution Mechanisms More Effective;
    • Part V – Improving Dispute Resolution, MAP and Corresponding Adjustments, and Part VI - Arbitration of the MLI;
    • 2017 Update of Art 25 – MAP of the OECD Model and its Commentary.
  • Presentation of three landmark court cases on MAP:
    • India and simultaneous MAP and domestic court procedures (‘e-Funds’ case);
    • Denmark and refusal of MAP access on grounds of allegedly insufficient taxpayer information;
    • The Netherlands and generic application to similar cases of the result of an individual MAP case.


  • Prof. Hans Mooij L.LM
    • Independent Tax Advisor for Hans Mooij International Tax Consultant
    • Visiting Professor, International Tax Centre, Leiden University, The Netherlands
    • Chairman, TRIBUTE Foundation for international tax dispute resolution

Thursday, January 18, 2018

9:00 AM - 10:00 AM Mexico, USA and Canada
1:00 PM - 2:00 PM Brazil
3:00 PM - 4:00 PM London (GMT)
4:00 PM - 5:00 PM Amsterdam (CET)


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