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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 Journal2026https://doi.org/10.59403/1bmzastarticle
ABDC C
Weight
0.50

What the paper says

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.

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https://doi.org/https://doi.org/10.59403/1bmzast

Or copy a formatted citation

@article{alejandro2026,
  title        = {{Commodities, Quality Variants and Foreign Exchange Differences: The Tax Court’s Olam Argentina Ruling on CUP and Export Advance Treatment}},
  author       = {Alejandro Messineo & MaríaAgustina Salatino},
  journal      = {International Transfer Pricing Journal},
  year         = {2026},
  doi          = {https://doi.org/https://doi.org/10.59403/1bmzast},
}

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

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Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.