Greece vs “Agri Ltd”, july 2020, Court, Case No A 1514/2020

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A Greek MNE Group, “Agri Ltd”, was active and specialised in wholesale trade of agricultural machinery, parts and tools. In 2012 a German company was established by the group to distribute products in the Central European region. The pricing of the goods sold by Agri Ltd. to the German distributor was determined by testing the income of Agri Ltd using a TNMM.

Following an audit the tax authorities issued a revised tax assessment, where the pricing of the inter-company transactions had instead been determined by applying a traditional cost plus method where the German subsidiary was the tested party.

The resulting assessment was appealed by Agri Ltd.

Judgement of the Court

The court dismissed the appeal of Argri Ltd.

“Since the tax audit, documented and clearly concluded that the cost plus margin method should have been chosen for the sales of the applicant to its subsidiary, the findings of the audit, as recorded in the 18.12.2019 Partial Income Tax Audit Report, are considered valid, acceptable and fully justified.

Since it is clear from the above that the impugned income tax adjustment order was lawfully issued, the applicant’s contentions to the contrary are rejected as unfounded.”


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ΔΕΔ Α 1514-2020

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