There are two types of comparables: internal comparables, which are generated from transactions between related and independent companies, and external comparables, which are transactions between independent companies.
The procedure for claiming Form 720 fines will depend on the situation of each taxpayer: appeals in progress, appeals not lodged but penalties within the deadline for appeal and final penalties.
The consequences of failure to comply with Model 720 are disproportionate in view of the objectives pursued by the regulatory framework, which are to ensure tax control and the fight against fraud.
The Certificate of Representation of an Entity without Legal Personality is issued to a natural person as representative of an entity without legal personality, and is valid for two years.
The comparability analysis compares the circumstances of the related transactions with those of transactions between independent persons or entities that could be comparable.