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International tax control for 2022

The Ministry of Finance will put into effect the Annual Tax and Customs Control Plan for 2022, promoting a set of measures such as...
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The Ministry of Finance will put into effect the Annual Tax and Customs Control Plan for 2022, promoting a set of measures such as international tax control and the fight against tax-havens.

In this regard, the automated transfer pricing risk analysis system has been implemented, designed by the Central Delegation of Large Taxpayers, in collaboration with the ONFI (Oficina Nacional de Fiscalidad Internacional – National Office of International Taxation).

This system will compile available domestic and international information on the subject and will be periodically updated with new sources. It will also identify patterns of high tax risk behavior. This is based on the 360° strategy, which is part of the OECD Transfer Pricing Guidelines.

The objective of this strategy is to interrelate the different procedures that may affect the related-party transactions of a particular taxpayer in a way that ensures tax compliance and avoids disputes.

In addition to this, concerning the fight against tax havens, the inspection activities will ensure the correct application of the “anti-haven” rules existing in the regulations.

There will be an exchange of information on entities located in these territories that carry out easily offshoreable activities, from territories with no, zero, or very low corporate income tax rates to the countries of residence of the parent companies or beneficial owners, promoted by the OECD Forum on Harmful Tax Practices.

Source: Autopos 16/02/22

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