A Slovak company submitted transfer pricing documentation relying on a full-range benchmark, but tax authorities found 9 of 10 comparables lacked independence. The authorities conducted their own TNMM benchmark, concluded the controlled transactions fell outside the interquartile range, and adjusted pricing to the median. The Administrative Court dismissed the taxpayer's appeal in March 2025, upholding the assessment in full ... Read more

An Italian subsidiary paid service fees and royalties to its French parent, which the tax authority disallowed for non-compliance with the arm's length principle. The authority's benchmark study included a non-independent comparable, which Italy's Supreme Court found arbitrary and methodologically flawed. In 2021, the Supreme Court set aside the Court of Appeal's decision and remanded the case for re-examination, ruling the flawed comparable invalidated the entire assessment ... Read more

A Romanian dairy company challenged a transfer pricing assessment covering both production and distribution activities, arguing the tax authority improperly replaced market prices and that a forensic expert report supported its position. The Supreme Administrative Court dismissed the appeal in 2020, upholding the tax authority's use of the median and comparable companies, finding the expert's analysis insufficiently reasoned ... Read more