Tag: Sodexho

Venezuela vs. Sodexho, 15. Dec 2016, Tax Court of Caracas

Sodexho Venezuela had appealed an adjustment made under the Venezuelan transfer pricing rules. The tax authorities claimed that the interest rate charged by Sodexho on a loan, made to a related party outside Venezuela, was not at arm’s-length. The tax authorities claimed that when applying the CUP method and comparing the controlled transaction with an uncontrolled transaction, Sodexho Pass Venezuela should have used an active rate such as the prime rate. The tax court ruled that Sodexho had correctly applied the CUP method and therefore cancelled the transfer pricing adjustment ... Continue to full case