One of the lessons that the pandemic has left us is that, in the near future, the context may change radically and we must be prepared to face these changes. This is related to the importance of history as a science that allows us to know the past in order…
6,884 total views, 12 views today
Today, there is a general consensus that the basic strategic objective of modern Tax Administrations (TAs) is to increase the levels of voluntary compliance by taxpayers, through two main lines of action, on the one hand by providing facilities to those who wish to comply, and on the other hand…
3,374 total views, 6 views today
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,…
12,689 total views, 27 views today
General Anti-Avoidance or Abuse Clause (GAAR): its genesis and evolution in Tax Law. Legal certainty
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…
16,737 total views, 40 views today
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…
3,351 total views, 3 views today
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…
1,979 total views, 5 views today