Transfer pricing

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Transfer pricing

Multinational organizations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. The goal of Deloitte’s transfer pricing network is to help companies manage risks by aligning practical transfer pricing solutions with their overall global business operations and objectives, assist with strategic documentation to support their transfer pricing practices, and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results.

In January 2013, the new Income Tax contained in Book I of the Law of Tax Update which included for the first time in Guatemala "Special Valuation Rules Related Party", ie regulations Transfer Pricing entered into force. In May 2013 was published the Regulations of the Income Tax containing a wide regulation of the subject.

After being in force and applicable standards Transfer Pricing January 1 to December 20, 2013, on the latter date Decree 19-2013 of Congress to suspend the enforcement and application of the "Special Valuation Standards published Related Party "which will take effect again and apply from 1 January 2015. However, the suspension referred to the same Decree 19-2013 provides that during such suspension the tax authorities may request information regarding taxpayers Prices Transfer to form the necessary databases.

Under the "Special Valuation Rules Related Party" -Prices of transference, Guatemalan business transactions with its related non-resident parties that impact the tax base (income, costs and expenses) must be evaluated by observing the principle of free competition, for purposes of income tax.

Due to the above, and to meet the challenges of this legislation, the services currently our firm can lend to your business are:

  • Advice to meet the Transfer Pricing Regulations
  • Diagnostics Transfer Pricing
  • Tax planning Transfer Pricing
  • Transfer Pricing Study
  • In-house training on Transfer Pricing
  • Support SAT requirements Transfer Pricing, and
  • Advance Pricing Agreements with the Tax Administration

Dispute resolution: Examination defense and mutual agreement procedure/competent authority

Often it is the actions and responses in the initial stages of a tax authority enquiries or interviews that affect the course or outcome of a transfer pricing examination. Accordingly effective and efficient explanation of a business transfer pricing policies include early involvement of an experienced global team that has  practical experience of all levels of the tax authority process, from proposed adjustments by field agents, through Advance Pricing Agreements, administrative appeals, litigation and the MAP process. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP process. Our teams include transfer pricing MAP specialists from both countries in dispute teamed with professionals who specialize in local country requirements for indirect taxes, taxes imposed by local or state/provincial jurisdictions, international tax and interest calculations for late payment that invariably affect the outcome.

Business model optimization

The global economic environment is characterized by continuous improvements in technology, an urgency to adopt and implement best practices and processes, and the potential for legislative change. Assessing a multinational's global business model is no longer an optional exercise. Business Model Optimization (BMO) is the process of understanding the demands of operations and of tax law and integrating them into the business model. Deloitte provides high quality, customized tax and BMO services that focus on helping multinationals integrate operational and tax requirements in a scalable and sustainable way in order to help business leaders to make effective decisions on an after-tax basis.

Deloitte delivers business model optimization services using the BMO Insight methodology, a set of experience based approaches to developing solutions to a range of tax issues and opportunities.