ARPTe Ltd had paid a subsidiary for management services and use of intangibles.
The benefit of those payments were challenged by the tax authorities and an assessment was issued where these deductions had been denied.
An appeal was filed with the tax court
Judgement of the Tax Court
The Court set aside the assessment of the tax authorities and decided in favor of ARPTe Ltd.
According to the Court ARPTe Ltd had been able to provide sufficient evidence that the management services and intangibles provided by the subsidiary had actually benefited the company.
PUT-108755-15-2013 Jan 2019