Taxpayer wins Argentine verdict on technology transfer payments
October 22, 2008
Daniel Rybnik of EnterPricing says that taxpayers in Argentina should be aware of the different treatment of transfer pricing policies based on variable and fixed factors
Oleoducto Trasandino Argentina (an Argentine subsidiary of A&C Pipeline Holding Company, whch is owned by YPF and Empresa Nacional del Petróleo -ENAP-) operates a transAndean pipeline transporting crude oil from Argentina to Chile. It anticipated paying an "x" amount to a foreign technology transfer provider and ended up paying "x + n".
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