Economic design
We establish where value is created within the group, where the key decisions are made and which risks are effectively assumed. That analysis defines the return that corresponds to each entity.
Transfer pricing firm in Latin America TP Atelier
We design transfer pricing policies for groups with operations in Argentina, Chile, Brazil and other Latin American countries, and we prepare the documentation that defends them in each jurisdiction.
We reply within one business day.
CoverageArgentina · Chile · Brazil
WorkStrategy, design and documentation
Order of work
Tax architecture
We define the functional structure, the flows and the agreements between entities, on a consistent basis across the region. An efficient structure is only useful if it withstands a tax audit.
Empirical evidence
Only at this stage do methods, comparability analyses, adjustments and ranges come into play. The data validate the economic rationale defined in the previous stages.
Defense and continuity
The policy must be capable of being explained to any tax administration in the region, applied consistently in each financial year and adapted as the business grows.
Documentation confirms a decision already made. It does not replace it.
Approach
Transfer pricing is not corrected with documentation. It is designed properly from the outset.
Before proposing a policy we analyze the group's operations in detail: what functions each entity performs, what assets it uses and what risks it assumes. That analysis produces the economic rationale, and the rationale produces the documentation each jurisdiction requires.
Every engagement is led by a partner from beginning to end. Determining the return that corresponds to each entity requires knowing and understanding the business of the group in detail, and that work is neither delegated nor resolved with a standard format.
Transfer pricing policy design
Regional annual documentationLocal File · Master File · Country-by-Country Report
Reorganizations and regional expansion
Valuations
Tax audit support
Jurisdictions
Argentina
- Information return on international transactions (F. 2668)
- Transfer pricing study, or local file (F. 4501)
- Master information report, or master file (F. 2673)
- Country-by-Country Report
Chile
- Annual transfer pricing return (DJ 1907)
- Local file (DJ 1951)
- Master file (DJ 1950)
- Country-by-Country Report, or CbC (DJ 1937)
Brazil
- New regime aligned with the OECD Guidelines
- Arquivo Local, or local file
- Arquivo Global, or master file
- Country-by-Country Report
Others
- Rest of Latin America
- Coordination with headquarters
- Consistency across jurisdictions
In most groups the transfer pricing policy was never deliberately decided. It accumulated year after year, on the basis of what the previous provider did.
Contact
Tell us where the group stands
Three questions before your contact details. That way, the first conversation starts from the group's actual situation.
1The case
2Contact
No field in this step is required.
Only the email is required.
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