Intercompany transactions and the market value trap
The most important obligation for taxpayers under the transfer pricing regime is to demonstrate that transactions were conducted in accordance with the arm’s length principle,
The most important obligation for taxpayers under the transfer pricing regime is to demonstrate that transactions were conducted in accordance with the arm’s length principle,
On March 8, 2024, the VI Conference Cycle on International Taxation and Transfer Pricing took place, featuring some of the world’s leading professionals in the
L.C. Y L.D. Miguel Ángel García Piña International Tax Associate en QCG Transfer Pricing Practice S.C. On January 22, 2024, the Tax Administration Service (SAT)
It has been quite common to assume that market prices, and even the application of widely accepted “fair” asset valuation methods, are sufficient to comply