Court decision in General Motors Uruguay electrónico the importance of marketing intangibles, local market characteristics and local comparables in a comparability analysis María José Santos
By: Santos, María José
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Material type: 
ArticleSubject(s): PRECIOS DE TRANSFERENCIA | ADMINISTRACION TRIBUTARIA | ACTIVOS INVISIBLES | MERCADOS FINANCIEROS | JURISPRUDENCIA | URUGUAY
In:
International Transfer Pricing Journal v. 29, n. 4, 2022, p. 293-296Summary: December 2021, the first court case in Uruguay on the application of the current transfer pricing regulations was concluded. After a thorough functional analysis and providing voluminous evidence of more than 11.000 sheets, the tax administration succeeded in demonstrating the existence of marketing intangibles in the transaction under analysis. The judgment in this case recognizes the importance of local market characteristics as relevant comparability factors that have to be taken into account in the comparability analysis, especially in circumstances in which there is publicly available information on national enterprises that perform similar activities to the taxpayer.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2022/4-2 (Browse shelf) | Available | ITPJ/2022/4-2 |
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December 2021, the first court case in Uruguay on the application of the current transfer pricing regulations was concluded. After a thorough functional analysis and providing voluminous evidence of more than 11.000 sheets, the tax administration succeeded in demonstrating the existence of marketing intangibles in the transaction under analysis. The judgment in this case recognizes the importance of local market characteristics as relevant comparability factors that have to be taken into account in the comparability analysis, especially in circumstances in which there is publicly available information on national enterprises that perform similar activities to the taxpayer.
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