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Panamanian transfer pricing jurisprudence in the case of a worldwide pharmaceutical company electrónico perspective of the expert appointed by the court Enrique Díaz Tong and Raul Hurtado

By: Díaz Tong, Enrique.
Contributor(s): Hurtado, Raul.
Material type: ArticleArticleSubject(s): EMPRESAS FARMACEUTICAS | PRECIOS DE TRANSFERENCIA | PANAMA | JURISPRUDENCIA In: International Transfer Pricing Journal v. 29, n. 2, 2022, p. 135-143Summary: The Panamanian tax administration requested a financial audit of a worldwide pharmaceutical company and found inconsistencies between declared reports. The taxpayer appealed. The case addresses the perspective of the expert appointed by the court on the report the Administrative Tax Court relied on to exercise a ruling which would determine the total tax payable by the taxpayer. This article highlights the importance of maintaining substance in related-party transactions and symmetry in financial reporting.
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Resumen.

The Panamanian tax administration requested a financial audit of a worldwide pharmaceutical company and found inconsistencies between declared reports. The taxpayer appealed. The case addresses the perspective of the expert appointed by the court on the report the Administrative Tax Court relied on to exercise a ruling which would determine the total tax payable by the taxpayer. This article highlights the importance of maintaining substance in related-party transactions and symmetry in financial reporting.

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