Commodities, Quality Variants and Foreign Exchange Differences: The Tax Court’s Olam Argentina Ruling on CUP and Export Advance Treatment

The National Tax Court, the administrative independent jurisdictional body responsible for resolving the Federal Tax Administration tax assessments and hearing appeals by practitioners on matters involving federal taxes such as income tax, has recently ruled, in September 2025, in the Olam Argentina case on a transfer pricing adjustment concerning goods with “agreed quality” and foreign exchange differences arising from export advances.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2026-03-20
DOI
https://doi.org/10.59403/1bmzast
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

Commodities, Quality Variants and Foreign Exchange Differences: The Tax Court’s Olam Argentina Ruling on CUP and Export Advance Treatment

Alejandro Messineo, MaríaAgustina Salatino
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Commodities, Quality Variants and Foreign Exchange Differences: The Tax Court’s Olam Argentina Ruling on CUP and Export Advance Treatment

Alejandro Messineo, MaríaAgustina Salatino
article en

Abstract

The National Tax Court, the administrative independent jurisdictional body responsible for resolving the Federal Tax Administration tax assessments and hearing appeals by practitioners on matters involving federal taxes such as income tax, has recently ruled, in September 2025, in the Olam Argentina case on a transfer pricing adjustment concerning goods with “agreed quality” and foreign exchange differences arising from export advances.

International Transfer Pricing JournalVol. 33(2)
Openalex Percentile: Top 14%
Corporate Taxation and Avoidance
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