Slovenia vs “Seat Covers Corp”, August 2019, Administrative Court, UPRS Sodba I U 1042/2019-21

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Category: Shares and Dividends, Transfer Pricing Methods | Tag: ,
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The tax authority erred in considering that the owners obtained the economic benefit of lower prices than comparable market prices indirectly through the ownership of the related company, which is not apparent from the facts established in the present case. As a result of an error of substantive law, the tax authority did not make a finding of fact in that regard. However, if the substantive law is correctly applied, it will be necessary to establish whether the natural persons, the qualified owners (CC., D.D. and E.E.), had an actual economic advantage or whether they actually benefited from the advantages arising from the applicant’s dealings with the related company A. at prices below the comparable market prices.

 
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UPRS_Sodba_I_U_1042_2019-21-20.08.2019

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