A Tanzanian coffee exporter received cash advances from a Swiss company to fund coffee procurement between 2009 and 2011. The Tanzania Revenue Authority treated the parties as associates and applied transfer pricing adjustments under the Income Tax Act. The Court of Appeal dismissed the exporter's appeal in 2025, confirming the associate relationship, upholding the assessments, and excluding foreign exchange loss challenges as questions of fact rather than law ... Read more

Cargill Argentina channelled commodity exports through a Uruguayan branch, with AFIP issuing transfer pricing assessments for FY 2000–2003 using the sixth method, pricing transactions at the shipment date rather than the contract date. Argentina's Court of Appeal confirmed the Tax Court's decision, ruling mostly in favour of the taxpayer and finding that AFIP's methodology was not valid under the transfer pricing rules applicable at the time ... Read more

Cargill Argentine SA routed 98% of its commodity exports through a Uruguayan branch, with the Argentine Revenue Service repricing transactions using the sixth method based on shipment dates. The Tax Court ruled mostly in favour of the taxpayer in 2022, finding the sixth method was not enacted until 2003 and could not apply retroactively to fiscal years 2000–2003, though a partial adjustment on soybean oil sales to Russia was referred back for reassessment ... Read more