Transfer pricing audit examinations - what is yet to come

The National Tax Administration Service (Servicio Nacional Integrado de Administración Aduanera y Tributaria, SENIAT) has adopted a more aggressive posture towards tax evasion and infractions, under its Zero-Evasion Plan. The Plan was implemented at the beginning of 2004 as part of an extensive audit examination programme promoted by the government, intended to increase compliance of taxpayers with current and new tax regulations.