Transfer pricing in

Transfer pricing in taxes in tax administration, the PT is used to determine the taxable profits of corporate groups, for their international (transnational, importer, exporter) have divisions in other countries, since, if all group expenses occur in a country that collects taxes and the sale occurs in another that the charge or has lower tax rate, most of the gain will not be paying taxes or pay a lesser amount. In other words, a corporation can use the control he has over his bound overseas, to transfer taxation of a country with a higher level of taxes to one with a lower level. Therefore, the transfer pricing legislation focuses on a special on economic transactions between related or related parties when one party has fiscal domicile in one of the territories known as tax havens.Therefore, the most developed countries, which are part of the OECD (Organization for Economic Cooperation and Development) , and later other countries in the world, defined a methodological framework to identify, through the PT, prices or profit margins on transactions between companies controlled (linked economically), including those acquired abroad. The basis of this methodological framework is called "arm's-length principle", which essentially seeks to determine which would have been the price of the transaction or the margins obtained by the parties if all transactions had been conducted in a competitive market, this is, as if the transaction had taken place with or between unrelated parties.In this way, it seeks to nullify the effect of so-called "controlled transactions" which are those made between companies in a group and that, therefore, usually will not show a price equal to that same transaction would have if there had been with an independent party or on the open market. The provisions on the matter which house the principles enunciated by the OECD, force companies to choose from six different ways to evaluate compliance with the arm's-length principle for tax purposes. This reference is used as usual prices or margins of comparable transactions worldwide. Since comparisons are usually not perfect, you should make adjustments corresponding beads to make the comparison from operations or companies.If it is proved that the transactions were not made at price targets, the company must set up its tax base and pay the additional tax accordingly, as if the transaction had taken prices or margins to be obtained in a comparable transaction conducted between independent parties. For example, if an item is sold to a distributor in another country at a lower price charged by other companies selling the same item, the seller then returns should be calculated based on the usual price charged by these other companies, thereby increasing the tax base and therefore tax revenue. That is why companies engage in transactions with their foreign vincualdos, especially multinational companies are finding that the PT regulations are one of the tributaries that require special attention and planning.