ISSN 1684-9833 • Year 2 / Special Edition / May 26, 2011
The Executive Secretariat Informs CIAT/GIZ/OECD SAT of Guatemala Seminar-Workshop on Transfer Pricing and Exchange of Tax Information was Successfully Concluded Agenda CIAT/GIZ/OECD SAT of Guatemala Seminar-Workshop on Transfer Pricing and Exchange of Tax Information
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Experts and officials from 17 CIAT member tax administrations as well as from the OECD, GIZ and CIAT met in the city of Guatemala on May 2-5, 2011 to discuss transfer pricing and tax information exchange. Following significant technical and logistic coordination efforts by the CIAT Executive Secretariat, GIZ of Germany, the OECD’s Center for Tax Policy and Administration (CTPA) and SAT of Guatemala, the Seminar-Workshop on “Transfer Pricing and Tax Information Exchange” was inaugurated by the Superintendent of Tax Administration of Guatemala, Mr. Rudy Villeda Vanegas and the CIAT International Cooperation Manager, Mr. Isaác Gonzalo Arias Esteban. This initiative, framed within the international cooperation agreements signed between CIAT and the OECD’s CTPA, and CIAT and the GIZ of Germany was the result of a specific request to CIAT from the tax administration of Guatemala which is currently working in a plan to implement practices aimed at controlling abusive manipulation of transfer pricing and evaluating alternatives for establishing bases that may allow tax information exchange with other treasuries. The basic objectives of this activity were to make known achievements by the tax administrations of the CIAT member countries in the application of legislations for avoiding abusive manipulation of transfer pricing and international tax information exchange practices; promoting the discussion of criteria and alternatives for solving common interest situations, exchanging experiences for detecting harmful international tax planning schemes, identifying best practices and promoting the expansion of the network of experts on the subject that has been developed by the GIZ of Germany.
eCIAT Panel of SPeakerS CIaT/GIZ/oeCD SaT of Guatemala Seminar-Workshop on Transfer Pricing and exchange of Tax Information
Dolores Gil Esnal Adviser to the General Deputy Directorate of Examination from AFIP of Argentina
Marcelo López Adviser International Tax Inspector from the DGI of Uruguay
Jairo Godoy International Examination Specialist from the SRI of Ecuador
Roberto Caparroz de Almeida Tax Auditor form the Secretariat of Federal Revenues of Brazil
Adriana García Martínez Customs and Tax Professional and Transfer Pricing Analyst from SENIAT of Venezuela
Franck Duval Head of Division at the Inter-regional Tax Audit Directorate of “Ile de France Est/Ouest” of the DGFIP of France
Víctor Gajardo Large Enterprises Examiner from the Large Taxpayers Examination Department of the SII of Chile
Wolfgang Büttner Transfer Pricing Adviser at OECD
Isaác Gonzalo Arias Esteban CIAT International Cooperation Manager, who lectured on “Key aspects for an effective tax information exchange”
Luz Myriam Martínez Parra Auditor from the DIAN of Colombia
Jörg Wisner Programs Director of the GIZ of Germany
Some of the main topics discussed were: • • • • • • •
2010 OECD Directives Formulation of transfer pricing examination plans Key aspects and case studies on International Tax Information Exchange Case studies on traditional and transactional methods on the benefit Case studies on Brazilian methods and methods for controlling transfer pricing in operations involving the import and export of commodities Negotiation of Advance Pricing Arrangements Experiences on the identification of reasonable and reliable comparables
The participating delegations included officials from the tax administrations of Dominican Republic, El Salvador, Haiti, Honduras, Jamaica, Kenya, Panama and Paraguay as well as a significant number of officials from the Superintendency of Tax Administration of Guatemala. The seminar-workshop was one of the greatest events co-sponsored by the CIAT Executive Secretariat on these subject matters, given the participation of 17 delegations from CIAT member countries, as well as representatives from the co-sponsoring organizations.
Based on the participation in the event, it may be said that there are ever more Latin American countries with experience on the matter, as evidenced in the significant number of speakers from the tax administrations of the region who shared their experiences. Some years ago, an event with these characteristics would have been impossible without the collaboration of the tax administrations from the developed countries. It was also perceived that there is a certain consensus on the part of the Governments of many Latin American and Caribbean countries in implementing legislations that may regulate the subject matters of the seminar-workshop and devoting resources for strengthening tax administration aspects that may allow for effectively applying such regimes. This was proven through the knowledge of the officials about the subject, the experiences presented and the accuracy with which they posed their needs and the steps to be followed. The closing remarks of the seminar were made by Mr. Manfredo Chocano, Institutional Planning and Control Manager of SAT Guatemala, Mr. Wolfgang B端ttner from the OECD and Mr. Gonzalo Arias, from CIAT. After the Seminar-Workshop, a meeting was held in the city of Antigua, Guatemala, on May 6, wherein the expert speakers who attended the Seminar provided technical assistance on legal, practical and organizational issues to the SAT and Ministry of Finance officials in response to their requests and concerns.