Transfer Pricing in Latin America

We are pleased to present this guide prepared by our team of Latin American tax law experts, focusing on Transfer Pricing.

The growing Transfer Pricing dispute has become an increasingly significant concern for multinational companies operating in the region.

In this guide:

• We present a detailed analysis of Transfer Pricing regulations in Brazil, Chile, Colombia, Mexico and Peru, including pronouncements by tax authorities, administrative and/or judicial courts.
• We examine specific cases and important pronouncements in each country, such as the implementation of the OECD guidelines in Brazil, interpretations on investment funds in Chile, and the treatment of foreign branches in Colombia.
• We address formal Transfer Pricing obligations and the challenges faced by companies, highlighting debates such as "substance over form" in Mexico and the active participation of the Tax Court in Peru.