Countries: El Salvador

El Salvador vs “E-S Cosmetics Corp”, December 2020, Tax Court, Case R1701011.TM

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“Cosmetics Corp” is active in wholesale of medicinal products, cosmetics, perfumery and cleaning products. Following an audit the tax authorities issued an assessment regarding the interest rate on loans granted to the related parties domiciled in Cayman Islands and Luxembourg. An appeal was filed by the company. Judgement of the Tax Court The court partially […]

El Salvador vs “E-S. Sales Corp”, December 2020, Tax Court, Case No R1705038.TM

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Following an audit the tax authorities issued an assessment regarding various intra group costs of sales deducted for tax purposes by “E-S. Sales Corp”. An appeal was filed by the company. Judgement of the Tax Court The court partially upheld the assessment, but in regards of application of the OECD Transfer Pricing Guidelines, the assessment […]

El Salvador vs Distribuidora Salvadorena de Petroleo S.A. DE C.V., September 2013, Supreme Court, Case No 386-2010

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Distribuidora Salvadorena de Petroleo S.A. DE C.V. (DSP), is active in “the wholesale and retail marketing of oil, derivatives, gas, lubricants, additives and energy in general. Following an audit the tax authorities issued an assessment regarding sale of oil. According to the authorities the prices determined by DSP for oil sold to a related party […]