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.
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