Argentine Tax Court case provides guidance on application of “functional relationship concept” for transfer pricing [TAX ALERT]

July 30, 2013

Transfer pricing rules in general, are applicable to transactions between related parties. Several countries also include as part of the transfer pricing test, the transactions with unrelated entities located in tax havens.

Noticeably, certain South American countries, starting with Argentina, also include the so-called “functional relationship concept.” A recently announced Argentine Tax Court case (Akapol S.A. – National Tax Court Room “A,” dated 03/15/2013) provides some guidelines regarding this concept.

Further details are available from the Ernst & Young Tax Alert which can be accessed using the link below:

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