Income Tax Law – Considerations by the inspection for Related Operations

Nov 21, 2023 | Tax Flash

The Supreme Court, in the statement dated June 21st, 2023, has confirmed the TEAC criteria and considers that, when the services provided by the partner to the related party, and the service that the this entity provides to third parties is substantially the same, and the mentioned entity does not has the resources to provide the services, if it is not for the necessary and essential participation of the person (partner), not providing added value (or this being residual), it is correct to consider that the payment agreed in the transaction with third parties is an unrelated comparable transaction.


Access to the full statement HERE

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