TPA Global LATAM Desk

Transforming the World of Tax

TPA Global introduces TPA Global LATAM Desk. TPA Global LATAM Desk specializes in the development and implementation of LATAM Transfer Pricing systems to assist multinational enterprises (MNEs) to proactively and efficiently manage and implement their transfer pricing policies in a cost-effective, practical and swift manner; ensuring compliance with local transfer pricing legislation across Latin America (“LATAM”).

TPA Global LATAM Desk will be happy to discuss with you the following solutions:

1. Country-by-Country Reporting, Master File, Local File and “Pan-LATAM Master File"

• Preparation and implementation of Country-by-Country Reporting, Master File and Local File, which do not only follow the general OECD model, but also meet the particular requirements of each country.
• Preparation and implementation of a "Pan-LATAM Master File". TPA Global offers the possibility of developing a "Pan-LATAM Master File" as a useful tool to centrally address the most relevant transfer pricing issues which should be considered by all companies of the Group in LATAM, irrespective whether the particular country at stake has implemented the BEPS elements mentioned above, or not, This tool ensures adherence to the Group's global transfer pricing policies and, simultaneously, results in a document that is easily adaptable to local transfer pricing requirements in each country in an efficient and cost-effective manner.

2. Other local requirements & transfer pricing forms

TPA Global LATAM Desk also offers assistance in the preparation of the local files. The aim of our service is to ensure that all the documentation is in line with the requirements and particularities of each domestic transfer pricing system (e.g. Transfer Pricing Forms, Transfer Pricing Studies). For this reason, TPA Global recommends using the "Pan-LATAM Master File".

3. Support in transfer pricing audits

TPA Global LATAM Desk can advise you on the effective management of a transfer pricing audit in LATAM. From the defense of your transfer pricing documentation to the management of communication with the local tax authorities, our team will be willing to design a personalized approach for your company.

Furthermore, TPA Global LATAM Desk has experience in assisting multinational enterprises (MNEs) with operations in LATAM with the following key aspects in a centralized and coordinated manner:

• How to produce transfer pricing documentation for LATAM in a cost-effective manner?
• How to align the Group’s transfer pricing policies with those of affiliated companies in LATAM?
• How to produce segmented financial data for evaluating the arm’s length nature of intercompany transactions with LATAM affiliates?
• In addition to producing a local transfer pricing report, which additional formalities must be addressed to mitigate the risk of non-deductibility of related party transactions with LATAM affiliates?
• How to effectively manage and use highly confidential information regarding a MNE’s intellectual property for preparing transfer pricing documentation for LATAM intercompany transactions?
• What would be a practical and efficient approach to setup a cash-pool structure for LATAM operations?

A free-of-charge consultation session is currently open upon request.

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For a list of LATAM countries with an APA programme in place please call our professionals.