Friday, 11 May 2012

Argentine National Tax Court sustains taxpayer position on appeals decision: the importance of the proof in transfer pricing issues

Early in 2010, the National Tax Court (NTC, an administrative instance dependent on the Executive Branch) ruled in favor of Aventis Pharma SA (Aventis), regarding an ex-officio assessment income tax for FY2000 levied by the Tax Authority in connection with transfer pricing issues.
During the tax audit, the Tax Authority rejected two comparability adjustments to the results of the tested party (Aventis) and also rejected one comparable from the set of comparables selected to test the transfer prices of the manufacturing segment, using the Transactional Net Margin Method (TNMM).
Source & more info: PKN