In recent years, the risks posed by transfer pricing have demanded increasing attention from the tax administrations of Latin American and the Caribbean countries.

This attention might be the result of various developments such as the convergence process through which transfer pricing rules have been disseminated (especially after the issuance of the Report on Action 13 of the Base Erosion and Profit Shifting (BEPS) project), or, due to the tax compliance risk that this issue represents for the economic sectors in the region.

For example, the asymmetries in the tax burden (Tax Paid/GDP) between Latin American and Caribbean countries of approximately 10% to more than 30%, generate an environment that promotes profit shifting within the region. The experiences and knowledge acquired by tax administrations has been facilitating the progress and further development of this field in the region.

However, the data presented in this book shows a notorious difference in the transfer pricing achievements between Latin American countries and the Caribbean countries. This is logical considering that the transfer pricing control rules have been in force for more than two decades in Latin America while only for a few years in some Caribbean countries.

The transfer pricing rules in question vary greatly from one country to the next; some tailored to meet specific characteristics while others are more aligned with the ‘Transfer Pricing

Guidelines for Multinational Enterprises and Tax Administrations’ by the Organization for Economic Cooperation and Development (OECD), hereafter known as the ‘OECD Transfer Pricing Guidelines’.