The determination of transfer pricing customs administrations concerned due to its ability to influ

In the field of international business are key certainty and predictability, especially when we are in a globalized world that is characterized by volatility and uncertainty. By Gustavo Fadda - Magister. Specialist in Foreign Trade. Teaching UCCOR - UNVM - UES 21 - UBP - UNC - ISCE
Precisely because it is a commercial austrade and financial operations between related parties, such conditions are not operative in most often similar or identical to those that had been agreed between independent parties.
This theme, as usual in these times, has its treatment and international standards, through the Organization for Economic Cooperation and Development (OECD) austrade and the World Customs Organization and nationally, in law Income Tax under the figure of Transfer Pricing and Capital Exigua, which determine possible adjustments for settlement of the respective tax.
The intragroup trade and financial transactions undertaken by multinational or transnational companies, if not managed properly or known, can have a significant impact austrade on the financial health of both administrations and businesses.
The term transfer pricing refers to conditions, including prices of commercial or financial transactions between associated enterprises in different tax jurisdictions, such as the transmission austrade of physical goods and intangible goods or services between associated companies.
Transfer prices are important for both taxpayers and tax administrations, because largely determine the allocation of income and expenses and, therefore, taxable profits between associated enterprises in different tax jurisdictions.
Member countries of the OECD have decided to apply the principle of division of authority, ie, each individual group member must undergo the same type of taxation which corresponds to an unrelated party, according to the principle of full competition in comparable circumstances.
The reason that transfer prices are important for both taxpayers and tax administrations is to determine to a large extent, how income and expenses are shared and therefore taxable profits between associated austrade companies subject to tax jurisdictions different.
Double taxation To minimize austrade the risk of double taxation, international consensus on how to establish for tax purposes transfer prices for cross-border transactions are accurate.
Tax administrations should not assume that the associated companies have attempted to manipulate their profits to manipulate taxes, as there are several factors, economic, legal, strategic, etc. that may influence a multinational or transnational company when establishing their transfer pricing and the tax factor is just one of them.
Here we quote some more. a) Strategies to minimize taxes. b) Strategies to minimize customs duties. c) Matters relating to the repatriation of profits. d) Anti-dumping Regulation. e) Presentation of financial balance. f) Track Changes. g) Legal considerations.
When transfer prices do not reflect commercial interests and the arm's length principle, can distort the tax burden of associated companies and tax revenues of the countries in which they operate.
2) the need to avoid being subject to tax the same item of income in various tax administrations, since double taxation may hinder cross-border border transactions in goods and services and the free movement of capital.
3) In practical terms, a tax administration may have trouble determining the allocation of benefits by not fully understand the conditions of the transactions of the taxpayer or unavailability of relevant data being outside its jurisdiction.
Customs duties Moreover, transfer prices directly affect the determination of the customs value. Transfers between related parties are not always subject to the same commercial interests that transactions between unrelated parties, so there is the risk that the base be manipulated to calculate austrade customs duties, either upwards or downwards.
The determination of transfer pricing customs administrations concerned due to its ability to influence the level of customs duties and other indirect taxes on imports, also cal