The Colombian Supreme Administrative Court supports the inclusion of loss-making comparables if they maintain similar functional conditions, rejecting their automatic exclusion. This decision strengthens alignment with OECD guidelines and requires tax authorities to conduct more rigorous technical and economic analyses.
LATAM tax authorities are tightening transfer pricing controls with new obligations, audits, and alignment with OECD standards. At ALS Transfer Pricing, we offer expert advisory services to help companies anticipate risks, ensure regulatory compliance, and adapt their tax strategies across the region.
Brazil adopts the arm’s length principle and aligns its transfer pricing regime with OECD guidelines. The reform introduces new valuation methods, stricter documentation requirements, and penalties—marking a key shift for multinationals operating in the country. ALS offers strategic support for implementation and compliance.
The assignment of image rights between artists or athletes and their own companies raises complex tax challenges. Current case law supports these operations if they are valued at arm’s length, but requires personal income tax to be applied to income from highly personal services performed directly by the individual.
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The Italian Revenue Agency and the Supreme Court endorse the use of the full range as a valid criterion to determine the arm’s length value in transfer pricing. This position, aligned with OECD guidelines, strengthens legal certainty for multinationals and clarifies the use of full ranges over more restrictive approaches such as the median.