Through the investigation carried out by the tax collection agency it was verified that both the guarantor and the lender were incorporated abroad the same month that the local taxpayer obtained the first line of credit. Everything stays at home because the guarantor is the direct owner of the lender to which it contributes a growing capital, which allows the latter to increase the amount it lends over time. Likewise, the funds originally derive from loans from related firms at a rate of 0% and without a predetermined term.
With data from the exchange of information, the DGI verified that the direct owner of 99.75% of the taxpayer, according to its financial statements, values its participation at a value that coincides with the value of the loan, that is, it considers it as equity. and not as debt.
“It can be concluded that the financial operations in question are transferred between interposed related companies until they acquire the character of lines of credit. These operations usually serve to disguise a capital contribution as a loan, hiding funds from ‘self-loans’ through ‘back to back’ operations. in which the entity lends money that it later receives on loan”, sources from the Federal Administration of Public Revenues explained to this newspaper.
The complex networks of subsidiaries are usually set up to take advantage of transfer prices and international treaties, since interest payments to the foreign lender are covered by a lower rate to avoid double taxation. The irregular use of this mechanism is known as “treaty shopping” and is also under the scrutiny of the OECD.
The company in question belongs to the group of 222 firms that represent a third of the universe of the most important taxpayers in the country and that their sworn returns for the income tax for the period 2021 were presented with an amount of $0. In the AFIP they suspect that the “back to back” is also being used to facilitate access to dollars at the official price.
Source: Ambito
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