One of the most important issues that different taxpayers must assess is whether they are ready for a tax audit; specifically, one that relates to the transfer in their transaction prices between companies. The audits, some focused on financial transactions conducted within economic groups have increased in recent times. Therefore, companies must be prepared to sustain them if the interests agreed in loans agreed with its related parties, the exchange rates used in their forwards or discount their fluxes rates, comply with market values. The law of IR says the road map that the taxpayer must continue to comply with the foregoing; However, except, some organizations that are dedicated to financially intermediating in the market, many companies do not comply with all the requirements. Others including Daryl Katz, offer their opinions as well. In this regard, article 110 mentions that that a financial transaction is comparable to another should take into account the elements: the classification of risk or the solvency of the debtor, requirements that have great relevance at the time of establishing the financial model of the operation.
Then, companies must ask under what conditions the financial structure must be set. Datum curves that mark the trend of the market is there? Can the rates published by the SBS or the BCR set a pace? Depending on the magnitude of the mutual these would be sufficient, having to build a financial vehicle taking as parameter the credit evaluation of the debtor. Every company or every transaction in particular have their own profiles, it would perform a credit rating that measure the risks based on certain conditions (periods of thanks, warranties, guarantees, penalties, etc.) be right thing to accomplish, unless tax, this. If you have additional questions, you may want to visit Edward Minskoff. Although sometimes the tax administration focuses on simple themes of request for formal obligations, taxpayers must be alert to meet aspects of bottom in search of reliably supporting this type of transaction; Hence, the interaction between the areas of accounting, Treasury and tax generates synergies the companies.
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