Researcher · Transfer Pricing Advisor
I work on international taxation, transfer pricing, and the taxation of multinational enterprises, with a particular interest in profit shifting and the empirical evaluation of international tax rules.
I have nearly thirty years of professional experience in transfer pricing and international taxation, advising multinational enterprises and tax administrations across Latin America. My work has also included serving as an expert in transfer pricing disputes and controversies.
My academic research focuses on how multinational enterprises respond to differences in taxation across jurisdictions, particularly through profit shifting, transfer pricing, the location of intangible assets, and intra-group financing. More broadly, I am interested in BEPS, foreign direct investment, and the design and evaluation of international tax policies.
My professional and academic work are closely connected. I am particularly interested in using empirical economic analysis to study questions that arise in the practical application of international taxation and transfer pricing.
Research Lines
Quantification of profit shifting by multinational enterprises in Colombia using fiscal microdata (DIAN) and accounting microdata (Superintendencia de Sociedades). The first microeconometric estimate for a Latin American country.
Effect of the introduction of transfer pricing rules (Law 788/2002) and the adoption of BEPS recommendations (Law 1819/2016) on profit shifting. Difference-in-differences designs across multiple regulatory breaks.
Application of the Bartik instrument to multinational taxation: exogenous variation in the sectoral composition of global FDI as a source of identification for the causal effect of MNE presence on the tax gap.
A theoretical hierarchical optimization model integrating profit attribution (arm's length principle vs. standardized signals), case selection, sequencing of enforcement layers, and international coordination under Pillar Two.
A research program paper integrating four studies on profit shifting in Colombia: accounting-based matching, direct measurement with fiscal data, causal identification with a Bartik instrument, and an optimal enforcement model. 34 pages, 87 references.
The first microeconometric estimate of profit shifting using real fiscal data for Latin America. Combines tax returns (DIAN) with financial statements (Supersociedades), 2000–2020. Estimated shifting: COP 3,007 billion/year (~USD 1,229 million). Post-BEPS reduction: 68%.
Documents the multinational taxpayer paradox: MNE subsidiaries in Colombia report higher profits and effective tax rates than comparable local firms, reversing the pattern found in the international literature. PSM + CEM + DiD using Supersociedades data.
Causal identification of the effect of MNE presence on the sectoral tax gap using a Bartik instrument. Panel of 77 NACE Rev. 2 sectors using ORBIS data. Result: +1pp MNE presence → +0.65pp tax gap. Exposure threshold: 12%.
A hierarchical Stackelberg model deriving nine propositions on profit attribution, case selection, sequencing of enforcement layers, and international coordination. Parametrized exercises for Mexico, Brazil, Colombia, the U.S., and Pillar Two.
Background
Book in Progress
A graduate-level textbook for the Latin American market. Fifteen chapters completed. Covers the mechanisms of profit shifting, the empirical evidence, regulatory frameworks (OECD, Pillar One, Pillar Two), and policy responses for developing economies.
Contact
Bogotá, Colombia · Available for research collaborations, transfer pricing consulting, and teaching in international taxation.