transfer pricing in the case of Argentina when the case is FX
Taking into account that FX gains or losses generated have their origin in credits and debts, principally between related parties, it is extremely important to analyse those transactions to determine whether they have been made acting as non-related parties.
Although we do not know of any local precedent related to this subject, the analysis of transfer pricing is oriented to determine whether the interest rates related to a credit/debt of an Argentine resident company fulfil the arm's length principle.
On this subject, the tax authority may inquire not only about the computed interest, but the FX losses related to the interest and the principal, if it considers the rate agreed higher than a market rate, in the case of a loan
sábado, 2 de agosto de 2008
martes, 10 de agosto de 2004
International Tax or Foreign Tax?
International Tax or Foreign Tax?
It is difficult to select, in international taxation perspective, where to write International Tax and where to write Foreign Tax. We have developed for several years international tax blog and only later this foreign tax blog. In google, there are around the same number of searches with international tax and with foreign tax. Which to choose? Any suggestions?.
Regarding the selection between Tax International or Foreign Tax, then it is more easy, as Tax International is much less used.
It is difficult to select, in international taxation perspective, where to write International Tax and where to write Foreign Tax. We have developed for several years international tax blog and only later this foreign tax blog. In google, there are around the same number of searches with international tax and with foreign tax. Which to choose? Any suggestions?.
Regarding the selection between Tax International or Foreign Tax, then it is more easy, as Tax International is much less used.
martes, 10 de febrero de 2004
Spanish Tax Lawyers
Spanish Tax Lawyers
A blog about spanish tax lawyers (spanish-tax-lawyers) provides different news and opinions about spanish taxation and spanish law in English, for companies and individuals thinking to operate in Spain.
Spanish Tax Lawyers offers also guidance about investing in Spain.
A blog about spanish tax lawyers (spanish-tax-lawyers) provides different news and opinions about spanish taxation and spanish law in English, for companies and individuals thinking to operate in Spain.
Spanish Tax Lawyers offers also guidance about investing in Spain.
miércoles, 10 de septiembre de 2003
Tax International in perspective
Tax International in perspective
In tax international there are several ideas and news about international taxation relevant to companies and individuals, including tax international issues like fiscal residency or transfer pricing.
In tax international there are several ideas and news about international taxation relevant to companies and individuals, including tax international issues like fiscal residency or transfer pricing.
jueves, 10 de abril de 2003
Legal issues in Foreign Tax
Legal issues in Foreign Tax
For readers interested in legal questions there is a blog, legal, where you can find several opinions and news about legal issues in Foreign Taxation.
For readers interested in legal questions there is a blog, legal, where you can find several opinions and news about legal issues in Foreign Taxation.
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