SA Tropicana Europe's French permanent establishment was converted from a full-fledged manufacturer to a limited-risk contract manufacturer in 2009. French tax authorities challenged the restructuring as an abnormal act of management and issued reassessments for 2010–2013. The Administrative Court set aside the assessments, and the Douai Court of Administrative Appeal upheld that decision in favour of the taxpayer in August 2022 ... Read more

A Latvian company faced a tax authority challenge over whether equal shareholder influence constituted joint control triggering transfer pricing rules under Section 12(2) of the Corporate Income Tax Act. The Supreme Court ruled in favour of the taxpayer, finding that equal influence does not automatically imply decisive influence or joint control, and that specific circumstances must be identified to establish concerted action ... Read more

An Italian bank paid interest on a bond subscribed by an Irish group entity, with a spread two points above market. Tax authorities disallowed the excess under IRAP rules, extending Article 11(7) TUIR via Law 147/13. The bank challenged the assessment on grounds of no controlling relationship at issuance and unconstitutional retroactivity. Italy's Regional Tax Court dismissed the appeal and ruled mostly in favour of the tax authority in 2017 ... Read more

A Latvian company's director, holding 25% of shares alongside his mother's 75%, was challenged by tax authorities over a related-party real estate transaction. The Supreme Court found the director lacked decisive influence over the company and was therefore not a related party. The court also assessed the quality of comparable transactions used to determine the apartment's market price, partially upholding and partially dismissing the taxpayer's appeal ... Read more