There are not many jurisdictional pronouncements related to transfer pricing . For this reason, every time the Administrative Litigation Tribunal (“TCA”) issues a ruling on this issue, it undoubtedly arouses the interest of those of us who deal with tax matters on a daily basis.
The case resolved by the TCA (Sent. No. 597/021) involves a Uruguayan corporation (hereinafter, “the Taxpayer”), whose main activity consists of importing and selling zero kilometer vehicles and spare parts of a famous international brand. to local dealers -not linked to the group-, who in turn resell them to final consumers in the domestic market and also in the Paraguayan market.
The Abogados.com.ar portal published the article and you can access the article through this link.
