Latin America: The Growing Prominence of Marketing Intangibles in TP Regulations and Disputes

This article provides an overview of the key concepts surrounding marketing intangibles and the way tax regulations and tax authorities in the region are tackling these issues. Careful consideration should be given to the possibility of requesting and negotiating unilateral or bilateral advance pricing agreements, in jurisdictions where this is a possibility, in order to achieve a robust level of certainty regarding the allocation of taxable income in the presence of marketing intangibles.

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