A Greek motor vehicle wholesale company was assessed additional income tax after authorities excluded comparable companies and adjusted results to the arm's length median, converting declared losses into taxable profits. The Administrative Court of Appeal upheld the adjustments, but Greece's Supreme Administrative Court reversed the decision in 2025, finding the lower court had incorrectly relied on a ministerial decision not applicable to the years under review ... Read more

A Greek motorcycle wholesaler challenged a tax authority adjustment that moved its tested operating margin to the median of a recalculated interquartile range for 2008. The Supreme Administrative Court ruled in favour of the taxpayer, finding that the 2008 legal framework created only a rebuttable presumption and that newly enacted transfer pricing rules could not be applied retroactively as a binding methodology for that year ... Read more

A Luxembourg company reduced its 12% intragroup loan rate to 6% and waived accrued interest on loans to its French subsidiary in financial distress. The tax authority requalified the waiver as a hidden capital contribution and excess interest deductions as hidden dividends. The Administrative Tribunal upheld the assessment in 2025, finding no evidence an independent lender would have accepted the restructured terms and noting the absence of an updated transfer pricing study ... Read more