Sustainability is redefining transfer pricing policies. ALS Transfer Pricing integrates ESG factors into multinational tax strategies through green intangible valuation, efficient cost allocation, and AI-based solutions to ensure compliance, consistency, and corporate reputation.
The 2025 Tax Control Plan strengthens transfer pricing oversight in Spain with a comprehensive approach: documentation review, automated risk analysis, and international cooperation. ALS offers expert advisory services to anticipate risks and ensure regulatory compliance with legal certainty.
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.