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  • Transfer Pricing

Precios de Transferencia


Fiscal developments follow from a series of economic, political and social factors, among which outstanding are the fiscal policy recommendations issued by the OECD which purpose is to achieve a broader and more systematic tax collection, in addition to seeking a more efficient inspection.

The transfer pricing obligation arises from the need for verifying transactions that multinational companies maintain with related parties and that they are in accordance with market prices and margins, i.e. that they have conditions similar to those that they had made with third parties and thus ensure that taxpayers settle their income tax based on the reality of their transactions.

We can collaborate with you on:


  1. Preparation of the Operations annex with related parties and Executive Letter.

Those who maintain accumulated operations with related parties greater than US$3 million during a fiscal year are required to prepare the Operations annex with related parties according to the formats established by the Internal Revenue Service.

Our service includes an Executive Letter of transfer prices that includes the methodology applied for the analysis and thus provide our clients with the necessary support for their OPRE Annex.


  1. Prepare the Integral Transfer Prices Report.

For cumulative transactions with related parties over US$15 million during the same fiscal year, taxpayers are required to file an Integral Transfer Pricing Report and the Operations Annex with related parties.

Our professionals prepare this study so that in addition to complying with tax regulations, your company can control its prices and policies with related parties.


  1. Advisory related to local transfer pricing rules.

We will resolve concerns about the particular application of local and international provisions around transfer prices by answering your consultations.


  1. Support during the inspection process by the Tax Administration.

We collaborate with the Companies in all the stages of tax assessments determined by the Tax Administration, in order to minimize possible contingencies.


  1. Strategy of definition of prices (planning).

Transfer pricing planning requires preparing a study in advance of the operation being performed, to establish starting from a business model the type of operation to be performed, the terms and conditions and the value or price. The key for designing a transfer pricing policy is that it be manageable and defensible.

With periodic reviews we identify if the company needs to make corrections in the prices established with its related companies during the course of the year, in order to comply with the principle of full competition.