Transfer Pricing provisions originate to establish principles and regulations to the costs or amounts agreed by multinational entities in their international transactions and their impact on the calculation of the income tax base. This is done, mainly, to avoid a detriment or deferral of the payment of taxes in each jurisdiction. The objective is that…
By: Gonzalo Manzano In a previous installment (see here), we discussed the evolution of the Organization for Economic Trade and Development (OECD) in reducing competition between different tax jurisdictions through the global standardization of tax rules, and in changing the policy that determines where companies must pay their taxes. The creation of the “BEPS Plan”…
By: Estefanía Ortuño When a corporation is incorporated, it is created with the intention of its permanence in time. This means that the spirit of a corporation, generally, is to survive even after the death of one of its shareholders. Therefore, the succession of shares will obviously occur sooner or later. Likewise, during the life…
By: Jean Paul Aguirre Transfer pricing is an extremely important regulation for any company, especially for those companies that are part of a corporate group with presence in different countries. Transfer prices refer to those amounts fixed between related parties for the transfer of tangible and intangible goods or services. The guiding principle is the…
By: Jean Paul Aguirre Once again, we address the importance of corporate stock transfer transactions; a topic that we have previously addressed in the series of articles on “Mergers and Acquisitions in Nicaragua” and “Tax Effects of Stock Transfer Transactions”. Recently, this topic has gained great relevance, since the legal system applicable to this type…
By: Rafael Luna The Transfer Pricing Guidelines were issued for the first time in 1995 by the Organization for Economic Cooperation and Development (OECD). Since then, there have been three updates, the first in 2010, the second in 2017 and the last in 2022. The Guides are mainly addressed to Tax Administrations around the world,…