Tag: EPSON

Seiko Epson Corporation is a Japanese multinational technology company headquartered in Suwa, Nagano, Japan. It manufactures and sells printers, projectors, industrial robots, and electronic components, operating through subsidiaries and regional headquarters across Europe, the Americas, and Asia.

Spain vs EPSON IBÉRICA S.A.U., March 2021, Supreme Court, Case No 390:2021

Spain vs EPSON IBÉRICA S.A.U., March 2021, Supreme Court, Case No 390:2021

/ Cost Contribution Arrangements, Disallowed Deduction, Tax Treaty Interpretation, Transfer Pricing Methods, Adjustment for stock options and pensions, Article 9, CCA/CSA, Corresponding adjustment, Cost Contribution Arrangement (CCA), Cost Sharing Arrangement (CSA), Disallowed deduction, EBIT margin, Employee costs, EPSON, Interpretation of international treaties, Pension costs, Transactional net margin method (TNMM), Transfer or secondment of employees
Epson Ibérica, the Spanish subsidiary of the Seiko Epson Group, sought to deduct pension contributions totalling over EUR 2.8 million made for a dual-role executive also employed by the Dutch parent company. The Spanish tax authority disallowed the deductions under transfer pricing and cost contribution rules. Spain's Supreme Court upheld the authority's position in March 2021, finding the costs failed the benefit test and were not properly allocated under the arrangement ... Read more
Spain vs EPSON IBÉRICA S.A.U., Feb 2018, Audiencia Nacional, Case No 314/2016

Spain vs EPSON IBÉRICA S.A.U., Feb 2018, Audiencia Nacional, Case No 314/2016

/ Arm's Length Principle, Cost Contribution Arrangements, Article 9, CCA/CSA, Cost Contribution Arrangement (CCA), Cost Sharing Arrangement (CSA), Employee costs, EPSON, Transactional net margin method (TNMM), Transfer or secondment of employees
Epson Ibérica deducted the full pension costs of a CEO shared with its Dutch parent, but Spanish tax authorities disallowed 90% of those costs based on the agreed salary split. The Spanish High Court upheld the assessment in 2018, ruling that the same 90/10 allocation applied to the CEO's bonus should logically govern his retirement package costs, rejecting the subsidiary's claim to deduct the full amount ... Read more