Please comment on Court rulings in LatinAmerica (except Mexico) drawn on the OECD Model Tax Convention or the OECD Transfer Pricing Guidelines.
posted by P. Sebastian Lopez-Sanson @ 4:59 PM
Sunday, May 07, 2006
International Taxation in Latin America
Please comment on Court rulings in LatinAmerica (except Mexico) drawn on the OECD Model Tax Convention or the OECD Transfer Pricing Guidelines.
Please comment on Court rulings in LatinAmerica (except Mexico) drawn on the OECD Model Tax Convention or the OECD Transfer Pricing Guidelines.
This blog is inteded to (i) provide the opportunity for Latin American tax practitioners to exchange their knowledge as to international tax issues arising in their home countries and (ii) give Latam int'l tax issues exposure for the outside world to keep updated on its current trends and developments
About Me
Sebastian López-Sansón graduated from Harvard Law School (2001-2002)/Int’l Tax Program (scholarship based on merit). He holds an LLM in Taxation, Univ. de Buenos Aires (2001) and J.D. degree, UBA, (1996); also pursued studies in Taxation at the Univ. de Salamanca (1997), Spain. Mr. López-Sansón is a Senior Int’l Tax attorney with O’Farrell Law Firm in Buenos Aires. Lately, he represented a client in a US$ 200MM leading case related to taxation of publicly placed securities and advised two public companies on sustaining a tax exemption on their US$ 1,1b publicly placed bonds. He currently renders tax advice to a global car manufacturer on a US$ 220 MM leading case related to int´l transfer pricing. He recently advised a utilities company on its US$ 350 MM debt restructuring and two retail enterprises on their transfer pricing policy. Lecturer on the “Latin American Tax Treaty Network”, Northwestern Univ. and Univ. Torcuato Di Tella joint Latin American Int´l Tax Program (2006). He was speaker in a number of conferences; among others, "The LatAm Tax Treaty Network as a Tool for Efficient Planning” and “Lessons Drawn from Transfer Pricing Litigation " (May, 2006)
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1 Comments:
In Argentina, there's "La Industrial Paraguaya", the "Taylor" case, several offshore fishing company cases. Also, the Argentine Tax Authorities have released a number of notices of deficiency drwan on the OECD Transfer Pricing Guidelines and the OECD Comments on the Model Tax Convention.
Than being said, please know that Argentina is not a party to the OECD but only one of the six observer countries.
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