The Resource Argentinian Supreme Court's landmark decision in intercompany loans in times of economic downturn

Argentinian Supreme Court's landmark decision in intercompany loans in times of economic downturn

Label
Argentinian Supreme Court's landmark decision in intercompany loans in times of economic downturn
Title
Argentinian Supreme Court's landmark decision in intercompany loans in times of economic downturn
Creator
Subject
Language
  • eng
  • eng
Summary
This article analyses whether a loan received by an Argentinian taxpayer, Transportadora de Energia SA, from a related company located in Brazil, CIEN SA, should be recharacterized as capital contributions due to the inability of the borrower to pay the maturities during the economic downturn of 2001. The importance of the case lies in the fact that the economic and financial crisis in Argentina 20 years ago has many parallels with the problems that the world is facing today with the COVID-19 pandemic
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 28 (2021), no. 1 ; p. 49-58
http://library.link/vocab/creatorName
Screpante, M.S
Geographic coverage
Latin America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • intercompany loan
  • economic crisis
  • case law
  • COVID-19 pandemic
  • GAAR
  • arm's length principle
  • expenses
  • deductions
  • BEPS Project (OECD)
Label
Argentinian Supreme Court's landmark decision in intercompany loans in times of economic downturn
Instantiates
Publication
Note
20210326
Other control number
itpj_2021_01_ar_1.html
Label
Argentinian Supreme Court's landmark decision in intercompany loans in times of economic downturn
Publication
Note
20210326
Other control number
itpj_2021_01_ar_1.html

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