1. Márcio F. Verdi Executive Secretary Interamerican Center of Tax Administrations Márcio F. Verdi Executive Secretary Interamerican Center of Tax Administrations Transfer Pricing Documentation Access to useful information

2. CONTEXT 100% of LAC countries have TP standards and have established an information regime Few Caribbean countries have provisions in this regard. THE GOODTHE BAD The current regimes of information are of little use - statement, study, etc. Little is known of relevant businesses in several countries The DTCs/TIAES increase exponentially Little is exchanged and there are no coordinated procedures in LAC In some countries banking secrecy or inability to identify owners of assets remain in force TAs believe that TP is a priority issue and gradually invest resources. Information is asymmetrical and scarce due to various circumstances. Most countries use commercial databases, Osiris being the most used. Some countries have access to horizontal cooperation based on transparency standards. Internal comparable are very hard to find and the external do not abound

3. WHAT INFORMATION IS NECESSARY FOR THE TRANSFER PRICING CONTROL? PROCESSES FOR WHAT? RISK MANAGEMENT CONTROL WHAT INFORMATION EXISTS TO COMPLY WITH THE “ARM’S LENGTH” PRINCIPLE? WHAT HAPPENS IN LAC?

4. Information Regime of large companies in 5 LA countries

6. The road to CBCR What is the level of knowledge in the region? What concerns exist?

7. Level of knowledge and some data from the region according to CIAT/TJN What some LA countries do? The agreement was signed by 3 countries Only 50% reported having an extensive knowledge 87% needs are satisfied by CBCR 75% require adjusting standards Access: 20% TAs 30% central DB 50% subsidiary

8. What are the remaining concerns? Maturity Number of countries that implement CBCR Risk management Threshold Adjust the current regimes Modify rules Cooperative compliance Dispute resolution Access to information Resistance of local companies Control/ Audit