References
  • Corporate Tax Law No. 5520, art. 13
  • OECD Transfer Pricing Guidelines
  • OECD BEPS Action 13
  • Pillar Two Global Minimum Tax Framework
  • ECB Working Paper No. 3071

International tax planning sits at the intersection of lawful efficiency and the question of where economic activity is genuinely performed. Current standards look beyond contracts and invoices to decision-making, people, assets and the actual allocation of risk.

Why substance matters

A structure is defensible when stated functions match day-to-day operations. The benefit test, pricing method and evidence file for intragroup services should therefore be designed together.

A management agenda

Tax policy is a shared responsibility of finance, legal and operations. Recurring risk reviews and current documentation provide stronger protection than building a defence after the fact.

This is a concise starter edition adapted from FAIR YMM’s existing technical archive for the new website.

Open archived source

This content is for general information only and does not constitute legal or tax advice for a specific matter.