Transfer Pricing Case Laws
US Supreme Court denies Whirlpool’s request for judicial review of the 2021 judgement from the Court of Appeal.
21 November 2022 the US Supreme Court denied Whirlpool its request for judicial review of the December 2021 judgement of the Court of Appeal (Sixth Circuit). 10 August 2022 Whirlpool ...
TELE2 announces SEK 1,8 billion victory in Swedish Courts
In a press release dated November 7, 2022, TELE2 announced a SEK 1,8 billion win related to tax deductions for foreign exchange losses on intra-group loans, that had previously been ...
Caterpillar announces $740 million settlement with the IRS
In a press release dated October 27, 2022, Caterpillar announced that a $740 million settlement had been reached with the IRS related to tax issues for FY 2007 through 2016 ...
Credit Suisse enters EUR 238 million settlement agreement in France
A settlement agreement between the French Financial Public Prosecutor and Credit Suisse was announced in the Paris Court of Appeal 24 October 2022. The “CJIP” agreement brings an end to ...
Banca Generali announces EUR 45 Million Settlement with Italian Revenue Agency
Italian financial institute, Banca Generali, has signed a agreement with the Italian Revenue Agency, whereby the parties agreed upon the terms and conditions for the settlement of tax claims in ...
Uber-files – Tax Avoidance promoted by the Netherlands
Uber files – confidential documents, leaked to The Guardian newspaper shows that Uber in 2015 sought to deflect attention from its Dutch conduits and Caribbean tax shelters by helping tax ...
Rio Tinto has agreed to pay AUS$ 1 billion to settle a dispute with Australian Taxation Office over its Singapore Marketing Hub
On 20 July 2022 Australian mining group Rio Tinto issued a press release announcing that a A$ 1 billion settlement had been reached with the Australian Taxation Office. “The agreement ...
The Netherlands releases New 2022 Decree on application of the Arm’s Length Principle
On 1 July 2022, the tax authorities in the Netherlands published Decree No. 2022-0000139020 of 14 June 2022 containing local guidance on application of the arm’s length principle. The Decree ...