South America: Dealing with local complexity when applying global transfer pricing policies

Transfer Pricing Perspectives

Multinational corporations' frequent difficulty in aligning some of their global transfer pricing policies with local regulations across South America is often resulting in double taxation. That’s because, in certain areas, both the rules on the books and the tax authorities’ approach to intercompany transactions are at odds with certain OECD-compliant structures.

In this article we look at the issues in detail, country by country, and show why you must exercise special care when returning to central marketing or sourcing entities, or when applying royalties or shared services agreements.

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