Type of court: Constitutional Court

Liechtenstein vs D AG (formerly A AG), August 2021, Constitutional Court (Staatsgerichtshof), Case No 2021/029


In the course of an Austrian tax audit related party transactions between C GmbH, Austria, and D AG (formerly A AG), Liechtenstein, could only be traced on the basis of balance sheets and tax returns of A AG, Liechtenstein. In January 2019, the Austrian Federal Ministry of Finance (BMF), Vienna, therefore submitted a request for […]

Liechtenstein vs A c/o B AG, October 2017, Constitutional Court, Case No StGH 2017/079


In the tax return for FY 2014, A c/o B AG declared a asset loans to related parties (holding company C) in the amount of USD 67,322,417.76 and liability loans to related parties (shareholder) in the amount of USD 110,051,410.39. Furthermore, interest income of USD 1,917,825.02 and interest expenses of USD 1,894,410.39 were declared in […]

Portugal vs “ALP S.A.”, May 2005, CONSTITUTIONAL COURT, Case No 252/2005


ALP S.A. filed an appeal with the Central Administrative Court against a corrections made by the Tax Administration for FY 1992 under application of the arm’s length principle (contained in article 57 of the CIRC in Portugal). The Central Administrative Court dismissed the appeal. An appeal was then filed against this decision to the Supreme […]