A Dutch tobacco subsidiary faced transfer pricing corrections across tax years 2008 to 2016, with disputes over factoring costs, guarantee fees on listed bonds, and a licence termination. The Amsterdam Court of Appeal found factoring costs largely non-arm's length, accepted that Tobacco BV's derived credit rating matched the group's, and upheld most assessments and penalties, deciding predominantly in favour of the tax authority ... Read more

A Dutch company transferred receivables to a low-tax affiliated entity under a factoring arrangement, reducing its Dutch taxable base. The Amsterdam Court of Appeal accepted the arm's length defence, but the Dutch Supreme Court annulled that decision in 2025, finding insufficient reasoning on comparability, risk allocation, and business substance. The case was remanded to a different Court of Appeal for reconsideration ... Read more

A Dutch company transferred receivables to a low-tax affiliated entity under a factoring arrangement, reducing its Dutch taxable base. The Amsterdam Court of Appeal accepted the arm's length defence, but the Dutch Supreme Court annulled that decision in 2025, finding insufficient reasoning on comparability, risk allocation, and business substance. The case was remanded to a different Court of Appeal for reconsideration ... Read more

A Dutch tobacco group subsidiary faced corporate income tax assessments exceeding €2.8 billion annually for 2013–2016. The North Holland District Court found in 2023 that intra-group factoring fees overstated actual default risk, guarantee fees were non-arm's length, and a 2016 group reorganisation triggered a taxable transfer profit, deciding mostly in favour of the Dutch tax authority ... Read more

A Dutch tobacco group subsidiary paid annual guarantee fees of approximately €35 million to its UK parent under an EMTN bond programme. The tax authority issued substantial additional assessments for 2008–2010. The Noord-Holland District Court ruled the EMTN Programme fell outside the Umbrella Credit framework, upheld the implicit support benefit enjoyed by the core company, and found mostly in favour of the tax authority ... Read more