Transfer Pricing and Tax Controversies
Through an interdisciplinary team made up of lawyers, accountants, and economists, we provide a highly specialized tax advisory service in international transactions, involving both transfer pricing and customs valuation determinations.
We have also actively participated in the leading transfer pricing cases in Argentina, in relation to the automotive industry and the agro-export sector. Likewise, we have been involved in the main tax controversies before the Supreme Court of Justice of the Nation, regarding benchmarking of agro-commodities, comparability analysis, timing of the taxable event, and debt to equity recharacterization, among others.
Our transfer pricing practice provides, among others, the following services:
Transfer pricing studies: preparation and review, with a focus on regulatory compliance and risk mitigation.
Comprehensive tax advisory services, at both local and international levels.
Design of transfer pricing policies for multinational groups.
Country-by-Country Report (CbCR) and Master File: assistance with preparation and compliance with information-reporting obligations.
Audits and tax controversies: strategic advisory and defense before administrative and judicial authorities.
Joint Transfer Pricing Determinations (DCPOI): assistance with application and processing.
Customs valuation and disputes with the customs authority.
