Selection or Rejection of Potential Comparables
There is no systematic preference in the selection of one approach over the other, since in both cases reliable comparables can be obtained and even a combination of the two approaches can be used.
Internal and External Transfer Pricing Comparables
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 CJEU rescinds Model 720 sanctions for declaring assets abroad
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.
Transfer pricing comparability analysis
The comparability analysis compares the circumstances of the related transactions with those of transactions between independent persons or entities that could be comparable.
The new method of capital gains calculation
The new method for calculating capital gains tax will offer taxpayers the possibility of choosing between two options (objective and real method), being able to opt for the more favorable one, as long as the value of the land undergoes a real increase.