LuxCo TM sold trademarks to a newly established sister company. The price had been set at €975,000.
The tax authorities issued an assessment where the price had been set at €6,475,000 and the difference was considered to be hidden profit distribution.
The Administrative court ruled in favor of the tax authorities. LuxCo TM’s valuation had been based on wrong facts and assumptions.
Lux vs Luxco 10 dec 2015 33611