Panamanian Transfer Pricing Jurisprudence in the Case of a Worldwide Pharmaceutical Company: Perspective of the Expert Appointed by the Court

Abstract

The Panamanian tax administration requested a financial audit of a worldwide pharmaceutical company and found inconsistencies between declared reports. The taxpayer appealed. The case addresses the perspective of the expert appointed by the court on the report the Administrative Tax Court relied on to exercise a ruling which would determine the total tax payable by the taxpayer. This article highlights the importance of maintaining substance in related-party transactions and symmetry in financial reporting. © 2022, The authors.