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Abhinaya Ramanujam and Marco Heuer of Deloitte examine the transfer pricing questions raised when group financing comes under strain and outline a step-by-step framework for managing the analysis

I. Introduction

Economic substance has assumed an increasingly important role in international tax disputes. Its application, however, requires a clear distinction between the accurate delineation of the actual transaction, the substance-over-form principle, and other anti-avoidance doctrines. Conflating these standards can weaken both the taxpayer’s position and the legal basis for a tax adjustment.

SMPS Legal fortalece su práctica de Litigio y Consultoría Fiscal con Patricia López Padilla Barrera como consejera