Abstract

GUERRA BELLO, Gustavo. Inversión internacional y sistema tributario Apuntes sobre los precios de transferencia entre partes relacionadas como estrategia fiscal. Estud. Socio-Juríd [online]. 2006, vol.8, n.2, pp.9-25. ISSN 0124-0579.

Tax systems have been organized to guarantee the financial resources of states, but additionally they have become instruments of fiscal policy to promote national savings and investment. In seeking a proper balance, and considering globalization, tax systems allow economic agents to adapt their performance maximize profit; their strategies include the reduction of the tax burden. Taking into account that purpose conglomerates operating at world-wide level, have devised a series of strategies, such as transfer pricing, over international transactions between related entities, whose application improves their financial results. This practice represents a challenge to the control that tax administrators must exert.

Keywords : foreign investment; international tax law.

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