The economic benefit of the TI in cases related to Covid-19 is pay by the entity that protects the professional contingency of the company’s employees and will be charge from the day after the sick leave until the date of discharge.
There are two types of comparables: internal comparables, which are generated from transactions between related and independent companies, and external comparables, which are transactions between independent companies.
The procedure for claiming Form 720 fines will depend on the situation of each taxpayer: appeals in progress, appeals not lodged but penalties within the deadline for appeal and final penalties.
The consequences of failure to comply with Model 720 are disproportionate in view of the objectives pursued by the regulatory framework, which are to ensure tax control and the fight against fraud.
The comparability analysis compares the circumstances of the related transactions with those of transactions between independent persons or entities that could be comparable.