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Venezuela transfer pricing documentation guide

March 04, 2008

Katherine Pinzón, transfer pricing partner in Caracas for Ernst & Young, describes the Venezuelan government’s approach to transfer pricing documentation

Venezuela enacted transfer pricing rules in its income tax reform in 2001. After seven years in force, the Venezuelan tax administration (SENIAT) is conducting aggressive transfer pricing audits based on thorough examinations of the contemporary documentation established in the 2001 rules. The transfer pricing documentation that must be fulfilled and maintained by the taxpayer is established in articles 168 and 169 of the Venezuelan Income Tax Act, and is listed in detail as follows:




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