The reduction of barriers to international trade and the increase in bilateral and multilateral trade agreements, among other factors, have resulted in a global economy characterized by unprecedented levels of international trade. This new environment has led to an increase in foreign direct investment in various countries, and corporations or economic groups now account for a larger share of global trade (60%), with “intra-group” transactions estimated to represent approximately 50% of international trade among these corporations.
This environment, where the participation of corporations in international trade is becoming increasingly significant—given the variety of tax rates in different countries and regulations that may provide tax advantages to companies or sectors, allowing them to shift profits to countries with lower tax burdens, among other factors—makes the issue of transfer pricing particularly important and significant.
Uruguay has not been left out of this trend. Thus, since the introduction of the Tax Reform that established rules on the matter, the issue of intra-group services has been one of the most complex to analyze.
This seminar aims to present new tools for analyzing the following questions:
·When are we dealing with intra-group services?
·Which services should be considered intra-group services?
·How is the market value of intra-group services defined?
·What are "shareholder activities"?
·What is meant by "on-call" services?
·What is meant by contribution or cost allocation agreements (CCA)?
·Proposed Intercompany Services Regulations and the Simplified Method
The speaker is a professor at the University of Buenos Aires. He is an active member of the Argentine Association of Tax Studies. He participates in and leads talks and seminars on transfer pricing in various forums in Argentina and Chile, such asLegal Publishing, Editorial Errepar, the Argentine Association of Tax Studies, IFA, and Forum. He is co-author of the book "Transfer Pricing in Argentina," alongside CPA Cecilia Goldemberg, a partner at the law firm Goldemberg & Eguia Asociados.