The comparability analysis is defined in the glossary of the OECD Guidelines as: As with many transfer pricing concepts, making the aforementioned comparison may seem like a simple task, but in practice, it requires a deep understanding of the transaction to be analyzed and the identification of potential comparable transactions,…

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This clause is the power that the tax administration has to apply the tax regulations to the substance of the business, leaving aside the inappropriate forms used by taxpayers through which they have obtained an undue tax advantage. While for some authors and laws the avoidance or abuse is configured…

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The balance between Society and the State results in a relevant way from the satisfaction with the redistribution of the public service and from the equity in the distribution of the burden that compensates for it. Such equilibrium is based on a theory according to which Society and State owe…

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The social disorganization, derived from the calamities that currently affect especially the lower income classes, is aggravating the deterioration of the order that regulates social coexistence, with many violations of the rule of law. Throughout history, injustices have triggered disorders, which led to corrode the little harmony existing in humanity…

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In the tax scope, the word “certainty ” has a special value, although not a single internationally accepted definition. Therefore, it may be asked what we mean by “tax certainty”. An excerpt from a phrase by François-Marie Arouet (better known as Voltaire) on issues unrelated to taxation says ” ……

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Introduction Mandatory Binding Arbitration is an issue that has slowly been gaining attention and on which CIAT Member Countries must work to further develop their official position. Through our experience with developing CIAT member countries, we have identified various positive and negative arguments that may be influential for countries when…

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