Intercompany documentation and compliance support so your LATAM entity's related-party transactions hold up under local transfer pricing rules.
Transfer pricing rules require that transactions between related entities, including cross-border sales, management fees, royalties, and intercompany loans, be priced as if the parties were unrelated. Most Latin American jurisdictions with a foreign-owned subsidiary require some form of local file or informative return documenting how those prices were set, and the specific thresholds and formats differ by country.
NavviPal coordinates transfer pricing documentation and compliance for your LATAM entity, working from your group's intercompany structure to produce the local file, master file coordination, and informative filings each jurisdiction requires.
Regulatory driver
Brazil moved to OECD-aligned transfer pricing rules under Law 14.596/2023, mandatory from the 2024 tax year. Requirements and thresholds vary by country.
Transfer pricing documentation is the record a company keeps to show that transactions with related entities, such as a parent company or sister subsidiary, were priced on arm's length terms. Most jurisdictions require this to be prepared annually and available on request from the tax authority.
Brazil adopted OECD-aligned transfer pricing rules under Law 14.596/2023, mandatory from the 2024 tax year, replacing its prior fixed-margin methodology. NavviPal advises on how this affects intercompany transactions with a Brazilian entity.
It depends on whether each entity has related-party transactions and whether the local jurisdiction sets a materiality threshold below which documentation is not required. NavviPal reviews your intercompany structure market by market to confirm what applies.
Requirements and penalties vary by jurisdiction. Missing or inadequate documentation is typically identified during a tax audit and can result in pricing adjustments, penalties, or both, applied at the local tax authority's discretion.
Transfer pricing documentation supports the intercompany structuring your tax advisory engagement sets up. NavviPal coordinates the two so your documented pricing matches the structure your tax advisor has recommended.
Ya sea que estés constituyendo tu primera entidad LATAM o necesites soporte continuo de cumplimiento y contabilidad, NavviPal te tiene cubierto.