Examinando por Materia "Precios de Transferencia"

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    Precios de transferencia : un análisis de la normatividad colombiana a partir de las directrices internacionales de la OCDE
    (Universidad EAFIT, 2020) Calle Ardila, Elena; Vélez Villegas, Juan Esteban
    Transfer pricing has the main purpose of preventing taxpayers from modifying the pricing or profit margin of the transactions between economic asociates in order to stop the transfer of tax benefits and the tax base erosion in an artificial way. In the increase of international bussiness due to globalization, multinational enterprises have faced the issue of differences in the normativity of transfer pricing in different states, this makes it posible for taxpayers to incure in a doble imposition scenario. Because of this, the OECD (the Organization for Economic Cooperation and Development), as an international organization has created international guidelines in transfer pricing for multinational enterprises and tax administrations, which different states have decided to integrate into their law structure, although some haven’t, as the case of Colombia. The consequence of not having equal normativity in different states makes it easier for taxpayers to face doble imposition situations and for tax administrations to face tax evasion, discouraging foreign investment. It is important therefore to analyze both colombian normativity in transfer pricing and OECD international guidelines to find aspects which could generate a doble imposition or tax evasion situation, and to determine its actual consequences.