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.